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Tax Case: Macquarie's Interest Deductibility Minefield

Published on 01 Nov 05 by "TAXATION IN AUSTRALIA" JOURNAL ARTICLE

The Full Federal Court has upheld Hill J's decision at first instance in relation to the deductibility of interest payments on stapled securities. The majority did not, however, uphold Hill J's finding that even if the interest payments were deductible, Part IVA would have applied.

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Marcus Ryan CTA
Marcus is an Assistant Commissioner with the ATO in Sydney, and works in the Tax Counsel Network. He currently focuses on the tax aspects of corporate and banking and finance transactions and has more recently been involved in the ATO’s administration of the JobKeeper initiative. Prior to joining the ATO in May 2017, Marcus was a senior associate at Ashurst. He has over 19 years’ experience as a tax lawyer providing advice on both direct and indirect taxes to both Australian and foreign clients, across a number of industries and government enterprises. - Current at 30 November 2020
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