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Published on 06 Apr 06
by NATIONAL EVENTS, TAXATION INSTITUTE OF AUSTRALIA
Section 51 has been one of the most litigated provisions of our tax legislation. In 1997 it was replaced by section 8-1. This paper covers how these provisions have been interpreted and applied by the ATO and by the Courts since 1997 including consideration of:
general deductibility - what has happened since 1997?
demarcation or boundary issues with the remainder of the legislation
timing of deductibility issues
purpose and when it becomes relevant
how does all this fit with the Consolidation Regime?
Allan Blaikie FTIA is based in Sydney and is the Head of Clayton Utz’s National Taxation Team. With 35 years experience (including over a decade as a chartered accountant), Allan has advised extensively on a broad range of taxation matters. His clients include both Australian and international companies and organisations. He has presented numerous
papers on taxation matters, both here and overseas. He has been involved in the conduct of Part IVA appeals as well as in appearances before the
Part IVA Panel Current at 28 May 2008
The Tax Institute is a Recognised Tax Agent Association (RTAA) under the Tax Agent Services Regulations 2009.
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