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Money can't buy me love: The market value substitution rule


Topics include: when can the commisioner look beyond the terms of the agreement; has consideration been allocated to all relevant CGT events; understanding the proper legal effect of the transaction; sham transactions; market value substitution rules; cost base of a CGT asset; Burrill's case and market value.

Author profiles:

Christopher Sievers
Chris Sievers practises primarily in revenue law, with a particular focus on indirect taxes such as GST and stamp duty. Since being called to the Bar in 2001, Chris has developed a substantial advice practice and has appeared on behalf of taxpayers and the Revenue in numerous disputes in federal and state jurisdictions, including the High Court in Reliance Carpet and Qantas. Recently, Chris appeared for the Commissioner in Rio Tinto Services before the Federal Court and on appeal to the Full Federal Court. Current at 19 October 2016 Click here to expand/collapse more articles by Chris SIEVERS.
Author Photo - Grant Cathro CTA
Grant Cathro CTA
Grant is a Partner with Allens Arthur Robinson, practising extensively in the resources sector. He advises clients in relation to project structures, acquisitions and divestments, ATO audits and disputes. Grant has over 25 years experience in both resource rent tax and income tax issues Current at 17 February 2011 Click here to expand/collapse more articles by Grant CATHRO.

This was presented at CGT Still Crazy After All These Years.

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Individual sessions

Every step you take: CGT and anti-avoidance rules

Author(s):  Mark POOLE

Materials from this session:

CGT issues in corporate reorganisations: Case study solution

Author(s):  Amanda LECKIE,  Tony MORGANTI

Materials from this session:

Issues in corporate reorganisation

Author(s):  Michael ANDREW

Materials from this session:

Money can't buy me love: The market value substitution rule

Author(s):  Grant CATHRO,  Chris SIEVERS

Materials from this session:

Life after the Orica decision

Author(s):  Michael CLOUGH

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