Bibliographic record
Abstract
The nature of "goodwill" for tax purposes was an important issue in Australia long before the adoption of the Commonwealth income tax, with the relationship between goodwill and sales of business premises a central issue in colonial stamp duty assessments (and consequent litigation). Judicial precedents and doctrines were transferred into the income tax arena as a result of a provision in the first Commonwealth income tax law that allowed depreciation of goodwill associated with leasehold interests. Judicial views were subsequently refined when the nature of goodwill was considered in the context of small business concessions for gains on the disposal of goodwill and in an important case in which a vendor created a notional goodwill asset in the course of a financial arrangement. Importantly, since 1964, Australian taxpayers have not been able to depreciate the cost of any form of purchased wasting goodwill. The Australian tax position stands in contrast with that of the UK, Canada, the US and many other countries. This article reviews the concept of goodwill in Australian tax law and suggests allowance of depreciation of purchased goodwill would be a logical reform to make, contributing to better alignment of the law with benchmark income tax principles.
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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 | 0.014 |
| Meta-epidemiology (narrow) | 0.000 | 0.000 |
| Meta-epidemiology (broad) | 0.000 | 0.000 |
| Bibliometrics | 0.001 | 0.001 |
| Science and technology studies | 0.001 | 0.003 |
| Scholarly communication | 0.004 | 0.005 |
| Open science | 0.001 | 0.001 |
| Research integrity | 0.001 | 0.002 |
| 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".