Insolvency, tax and liquidation distributions: dividends, capital gains and the dead hand of the past
Bibliographic record
Abstract
Abstract Shareholders are normally entitled to the surplus, if any, which remains after a liquidator has paid off the company's creditors and discharged all of its outstanding liabilities. Surplus distribution to shareholders is an anticipated event in the liquidation of a solvent company. Shareholders in insolvent companies, by contrast, are likely to be pleasantly surprised to receive surpluses prior to the cancellation of failed investments. Taxation liabilities are likely to arise for the shareholders in both events—under independent and, to a degree, inconsistent regimes provided by the Income Tax Assessment Act 1936 (Cwth) (‘ITAA36’) and the Income Tax Assessment Act 1997 (Cwth) (‘ITAA97’). This paper analyses Australian taxation of liquidation surpluses, noting historical factors and the approaches taken in four comparable tax jurisdictions. Company law applicable to liquidation surplus distributions is surveyed by way of introduction. Copyright © 2006 John Wiley & Sons, Ltd.
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How this classification was reachedexpand
Full frame machine prediction
Teacher imitationNot calibrated prevalence, not ground truth. Human validation pending. The Gemma side is a direct model label for every work in the frame, read from the title-only record. The Codex side is a classifier learned from the 10,348 direct Codex labels and calibrated to design-weighted sample rates; fields without enough sample support carry no Codex call. Candidate is the union of the two sides; consensus is their intersection. These outputs are machine_predicted_unvalidated and are not human labels.
Distilled classifier scores by category (both heads)
| Category | Codex | Gemma |
|---|---|---|
| Metaresearch | 0.002 | 0.009 |
| Meta-epidemiology (narrow) | 0.000 | 0.000 |
| Meta-epidemiology (broad) | 0.000 | 0.000 |
| Bibliometrics | 0.001 | 0.002 |
| Science and technology studies | 0.001 | 0.002 |
| Scholarly communication | 0.002 | 0.002 |
| Open science | 0.000 | 0.001 |
| Research integrity | 0.001 | 0.001 |
| Insufficient payload (model declined to judge) | 0.006 | 0.000 |
Machine scores (provisional)
The two teacher heads of the student model, read on this work. A score orders the frame for review; it never asserts a category, and the validation status ships verbatim with every row.
Baseline scores from an immature model (maturity gate not passed, 7 training rounds). Scores rank; they never assert a category.
score_only:v0-immature-baseline · verbatim from the scoring run: score_only means the number may rank works, and no category label ships from itClassification
machine, unvalidatedMachine predicted; a candidate call from one source (direct Gemma or distilled Codex), not a consensus.
How this classification was reached, model by model and score by score, is at the end of the page under "How this classification was reached".