Catchwords
Taxation – Income tax – Share buy-back – Off-market purchase – Company's financial record of transaction – Whether dividend or capital gain – Whether purchase price "debited against amounts standing to the credit of … the company's share capital account" – Meaning of "share capital account" – Relevance of legislative history.
Words and phrases – "account", "buy-back", "combined share capital account", "debited against amounts standing to the credit of", "financial records", "financial statements", "purchase price", "share capital account".
Corporations Act 2001 (Cth) – Pt 2J.1 of Ch 2J, Pt 2M.2 of Ch 2M.
Income Tax Assessment Act 1936 (Cth) – ss 6D, 159GZZZP.