This convention paper analyses the structure of Part IVA and its characterisation of purpose. It also covers the application of the s.177D factors and the application of Part IVA to elections.
Des is the Special Tax Adviser at the Australian Taxation Office. Previously, he was Deputy Chief Tax Counsel for the ATO, a role he held from 1994 until 2011. His work includes advising on major public and private rulings and strategic litigation. Des has been Chair of the Public Rulings Panel and the General Anti Avoidance Rules Panel and currently chairs the International Steering Committee as well as the NTLG International Sub-committee. Current at 02 July 2012
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