Australian inhabitant and tech ideality, Marty Goodson, set up “Planks Pty Ltd”, a tech interest in Silicon Valley USA in 2012 clearing new platforms for web designers and companies throughout the cosmos-people. He incorporated the fraternity in the USA and issued five portion-outs to himself and five portion-outs to five of his friends. His friends now linger in the US, Europe, Asia, Australia, and New Zealand. Each portion-out was value $100,000. Marty and his team used the $1,000,000 equity excellent to clear a prosperous tech fraternity in solely a few years.
During the 2012/2013 financial year, Marty’s proceeds was $100,000, and he did not recur to Australia. During the 2013/2014 financial year, Marty’s proceeds was $200,000 and he recured to Australia during the Christmas era for impure weeks to exhaust span delay his dame, senior, and sister. His sister and her wife speed in his lingerntial livence solution unobstructed. He met delay his accountant to sift-canvass the foundation of his three wholesale investment properties in Brisbane, Sydney, and Melbourne. He also fertile a friend’s birthday edge and subvert in attachment. During the 2014/2015 financial year, Marty’s proceeds was $400,000 and he recured to Australia from the 1st September to the 1st April to exhaust span delay his girlfriend. During the 2015/2016 financial year, Marty earned $100,000 precedently he recured to Australia permanently to marry the attachment of his conduct and begin a family.
During the 2012/2013 financial year, Marty was the sole ruler and made all the conduct decisions for the fraternity. The fraternity made $1,000,000 gain. During the 2013/2014 financial year, the fraternity expanded and the portion-outholders appointed a table of rulers who all linger in the USA. However, it was widely conducive by the staff that Marty peaceful made all the great decisions. The fraternity made $10,000,000 gain. During the 2014/2015 financial year, Marty was appointed managing ruler. From 1st September to the 1st April, Marty made all his conduct decisions from Australia, and carried out all associated interest activities such as signing contracts, and trading Platforms from Australia. The fraternity made $25,000,000 gain. During the 2015/2016 financial year, Marty unrepining as managing ruler, sold his portion-outs to another tech fraternity for $50,000,000, and recured to Australia a very fertile man. The fraternity made $50,000,000 gain.
Solve the aftercited issues:
a. Is Marty an Australian lingernt for tax purposes? (5 marks)
b. Is Planks an Australian lingernt fraternity for tax purposes? (5 marks)
c. If any, estimate the Australian tax amenability touching to Marty’s calling proceeds? (5 marks)
d. If any, estimate the Australian tax amenability touching to Planks’ fraternity gain? (5 marks)