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Part IVA: black, white or grey?
Published on 01 May 97 by SOUTH AUSTRALIAN DIVISION, THE TAX INSTITUTE
In this convention paper the author looks at the High Court decision which upheld the Commissioner's submissions and overturned an earlier ruling of the Full Federal Court, which had held that the general anti-avoidance powers found in Part IVA of the Income Tax Assessment Act 1936 had no application to a scheme which took the income from an investment by two related Australian companies outside the jurisdiction of the Australian tax laws.
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This was presented at 1997 South Australia State Convention .
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