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The ATO is regularly issuing class rulings on the taxation impact of restructures resulting from corporate activity. Some of the ATO positions are favourable to taxpayers and some are not. In many instances the reasoning behind the ATO position is unclear or called into question by practitioners. Now is the opportunity to hear first hand some of the logic and reasoning of the ATO from one of its chief tax counsels intricately involved in developing the rulings. The ATO position is illustrated through a series of examples. This paper analyses:
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