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Tax risk management: rulings - real protection or a false sense of protection? paper


This paper covers:

  • the 'ATO advice' product offerings - private, public, product and class rulings
  • the effect of having a ruling, including 'Will it cover Part IVA?' and can it be relied upon?
  • withdrawal of a ruling - when and how?
  • material difference in the facts underlying a ruling - what is the impact?
  • where do ATOIDs fit?
  • is a ruling application likely to have consequential issues?
  • timing and cost issues
  • the need for completeness and candour
  • challenging the ATO position - is it better to tackle the ruling or the assessment?

Author profile:

Frank joined Corrs Chambers Westgarth in 1987, becoming a partner in 1994. Subsequently, he became a Practice Group Leader and was a Board Member prior to joining the Bar Leader and was a Board Member prior to joining the Bar in 2003. Frank’s practice at Corrs was, and the Bar is, a general commercial and taxation based practice. Frank was the National Chair of the Taxation Committee of the Law Council of Australia for 2005 and 2006, the Melbourne Chair of that committee for 2003 and 2004 and he is currently a Senior Fellow of the University of Melbourne teaching taxation subjects in the Graduate programme of the Law faculty.
Current at 28 September 2007 Current at 15 October 2007 Click here to expand/collapse more articles by Frank O'LOUGHLIN.


This was presented at 20th National Convention: Tax Unmasked .

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Individual sessions

Managing consolidation - the state of play and the resolution of major issues

Author(s):  Michael D'ASCENZO

Materials from this session:

Part IVA - a post-Hart report card

Author(s):  Graeme S COOPER

Materials from this session:


Author(s):  Peter MOLTONI

Materials from this session:

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