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Part IVA - Taxpayer Triumph!

Member Price: $57.00
Non Member Price: $75.00

DisclaimerThis material is copyright. Apart from any fair dealing for the purposes of private study, research, criticism or review, as permitted under the Copyright Act, no part may be reproduced by any process without written permission from The Tax Institute.
Unless expressly stated, opinions are not that of The Tax Institute, which accepts no responsibility for the accuracy of any of the information contained within it.

Published on 07 Jun 01 by WESTERN AUSTRALIAN DIVISION, THE TAX INSTITUTE

This seminar paper addresses the questions of Part IVA, including: May the taxpayer structure the transaction this way rather than that, especially as the tax outcome is more favourable?; Should the more favourable course of action only be chosen where the taxpayer is in a position to prove that the decision was not driven by the tax advantage?; Is the purpose of the taxpayer determined objectively or subjectively?
These and other issues were addressed in the decisions of the full Federal Court in Eastern Nitrogen Ltd. v. F.C.T and Metal Manufacturers Ltd. v F.C.T

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Rob O'CONNOR
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Part IVA - Taxpayer Triumph!

Author(s):  Rob O'CONNOR

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