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Part IVA...no limit to its operation?

Published on 01 Aug 03 by "THE TAX SPECIALIST" JOURNAL ARTICLE

This article details administrative issues raised relating to the purported determinations made by the Commissioner under Part IVA pursuant to which the 'mass marketed' project deductions were disallowed. These issues relate to the form of the delegation of the Commissioner's power, the timing of the issue of the determination, multiple and tentative assessments and the ability of the Commissioner to make a 'global' (project based) determination.

Author profiles

Jocelyne Boujos
Jocelyne is the Principal of Boujos Legal and Immediate Past President of the Law Society of Western Australia. She has practised in commercial and taxation law for over 30 years. She advises clients, including indigenous charitable trusts, in relation to taxation and trust matters including superannuation issues and estate planning. Jocelyne commenced practice in the Australian Taxation Office as Principal Prosecution Officer and Senior Advising Officer, and has lectured at the University of Western Australia in the Master of Taxation and Master of Business Administration degrees. She is a member of the Taxation Committees of the Law Council of Australia and the Law Society of Western Australia, a trustee of the Graduate Women Education Trust and has been a Certified Tax Practitioner – Taxation Institute of Australia. - Current at 28 January 2022
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Thomas Henn
Thomas specialises in Asset Protection, Estate Planning, Business Structuring, Trust, Tax and Superannuation. He worked as a lawyer in Germany before migrating to Australia where he worked with a number of top advisory and legal firms, including PricewaterhouseCoopers as a Tax Advisor, prior to joining Murfett Legal. He has lectured at Curtin University in Advanced Taxation for 8 years at the post-graduate level and was also the Managing Director of the first listed Australian law firm. Thomas is experienced with assisting high net worth clients, company executives and business owners with their estate and succession planning. His expertise is highly regarded in relation to all taxation arrangements including tax planning and structuring for trusts and private companies. He has successfully represented taxpayers in ATO interviews, objections and private ruling applications. - Current at 27 March 2012
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Modiesha Stephens CTA
Modiesha is a Director at MS Legal practicing in Taxation, Commercial Law and Estate Planning. Modiesha has over 25 years’ experience in advising SME and individual clients in all areas of State and Federal taxation with a particular emphasis on transactional tax advice, including income tax, CGT, GST, transfer duty and other State taxes. Modiesha also practices in estate and succession planning and general commercial law. In addition to being a Chartered Tax Adviser, Modiesha has degrees in law and commerce and a Master of Laws. Modiesha is an avid supporter of the Tax Institute having served on various committees over the years and is the current WA representative on National Council. - Current at 04 November 2025
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