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Part limit to its operation?


This article details administrative issues raised relating to the purported determinations made by the Commissioner under Part IVA pursuant to which the 'mass marketed' project deductions were disallowed. These issues relate to the form of the delegation of the Commissioner's power, the timing of the issue of the determination, multiple and tentative assessments and the ability of the Commissioner to make a 'global' (project based) determination.

Author profiles

Modiesha Stephens CTA
Modiesha Stephens, CTA, is a Senior Associate at HHG Legal Group. She has been practicing in State and Federal taxation for over 15 years focusing on providing transactional tax advice to clients covering Income Tax, CGT, GST, Transfer Duty and other State taxes and assisting with tax litigation. Modiesha is also an experienced general commercial lawyer who advises clients in all stages of their business lives as well as assisting them with their Wills and Estate Planning. Before joining HHG Legal Group in July this year, Modiesha worked at a number of boutique law firms including Munro Doig where she worked for 10 years. In addition to her law and commerce degrees Modiesha has a Masters of Law - Current at 01 September 2016
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Jocelyne Boujos CTA
Jocelyne is a principal of Sceales & Company lawyers. The firm practices in taxation (Federal and State) and superannuation matters. It has a large practice in commercial work, property, conveyancing, estate planning, wills and probate matters, administration of estates including deeds of arrangement. Jocelyne graduated from UWA with a B. Juris and LLB and started practice within the Australian Taxation Office. She advises clients, including indigenous charitable trusts, in the areas of taxation, trusts, superannuation and estate planning and on managing ATO compliance activity, rulings and tax dispute resolution. Jocelyne has a long involvement with professional education including lecturing in Master of Tax programs. She is a member of the Society of Trust and Estate Practitioners and of the taxation committees of the Law Council of Australia and the Law Society of Western Australia, and, is a trustee of the Graduate Women Education Trust. - Current at 16 July 2015
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Thomas Henn CTA
Thomas specialises in Asset Protection, Estate Planning, Business Structuring, Trust, Tax and Superannuation. He worked as a lawyer in Germany before migrating to Australia where he worked with a number of top advisory and legal firms, including PricewaterhouseCoopers as a Tax Advisor, prior to joining Murfett Legal. He has lectured at Curtin University in Advanced Taxation for 8 years at the post-graduate level and was also the Managing Director of the first listed Australian law firm. Thomas is experienced with assisting high net worth clients, company executives and business owners with their estate and succession planning. His expertise is highly regarded in relation to all taxation arrangements including tax planning and structuring for trusts and private companies. He has successfully represented taxpayers in ATO interviews, objections and private ruling applications. - Current at 27 March 2012
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