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TD 92/178 - Income tax: is that part of the total cost incurred by Co A in acquiring shares in a third unrelated Co from Co B under an underwriting agreement, and claimed as interest by Co A, deductible under section 8-1 of the Income Tax Assessment Act 1997 if: (a) Co A treated the shares acquired as being on capital account; and (b) the underwriting agreement provided that the total acquisition cost was to include an amount expressed to be interest in relation to the period during which the agreement was current?    

Legislation Cited

Cases and Articles Cited

Case Name	Citation(s)	Court	Jurisdiction	Date †	Full Text		Citation Index
Re Farm Security Act 1944 of the Province of Saskatchewan	[1947] SCR 394			circa 1947			25
Sun Newspapers Ltd v FCT	[1938] HCA 73; (1938) 61 CLR 337; [1939] ALR 10; 5 ATD 87; (1938) 1 AITR 403	High Court of Australia	Australia - Commonwealth	23 Dec 1938	AustLII		398
Federal Wharf Co Ltd v Deputy FCT	[1930] HCA 30; (1930) 44 CLR 24; 36 ALR 349; 1 ATD 70	High Court of Australia	Australia - Commonwealth	22 Sep 1930	AustLII		34