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Part IVA Rulings - TR 2002/18 and TR 2002/19 presentation

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Published on 18 Mar 03 by SOUTH AUSTRALIAN DIVISION, THE TAX INSTITUTE

These tax rulings highlight the application of Part IVA of the ITAA 1936 to deny tax benefits associated with tax avoidance schemes.

TR 2002/18: INCOME TAX: HOME LOAN UNIT TRUST ARRANGEMENT
- examines arrangements where a taxpayer acquires a residential property through a unit trust and seeks to claim interest deductions for what is essentially private expenditure
- illustrates how Part IVA will apply to strike out tax benefits resulting from this arrangement.

TR 2002/19: INCOME TAX: LICENCE ARRANGEMENTS FOR INTELLECTUAL PROPERTY - DIVISION 40 - TAX AVOIDANCE SCHEMES
- examines arrangements under which a taxpayer obtains tax deductions under Division 40 in connection with the commercialisation of intellectual property where the taxpayer has little or no financial exposure to its success or failure
- illustrates the application of Part IVA to these arrangements.

Author profile

Brett Zimmermann CTA
Photo of author, Brett ZIMMERMANN Brett Zimmermann, is an Assistant Commissioner in Tax Counsel Network (TCN) responsible for providing leadership on technical issues that are a priority for the ATO. Brett joined the ATO five years ago, prior to that working 18 years in the private sector as a specialist tax and commercial solicitor. Brett holds a range of roles in the ATO and deals with issues during audit, advice products, litigation and legislative development with a focus on corporate transactions. His recent work includes matters pertaining to current R&D, share capital management and earnout portfolios. Brett was the TCN Assistant Commissioner with technical responsibility for the GQHC, Sunlite and TDS Biz litigation matters. - Current at 14 March 2024
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Individual sessions

February 2003 developments

Author(s):  Nikki HASSOUROS

Materials from this session:

Part IVA Rulings - TR 2002/18 and TR 2002/19

Author(s):  Brett ZIMMERMANN

Materials from this session:

GST Update - March 2003

Author(s):  Kristian THOROUGHGOOD

Materials from this session:

Further details about this event:

 

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