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Part IVA and restructures paper

Published on 28 Feb 13 by QUEENSLAND DIVISION, THE TAX INSTITUTE

The proposed amendments are here and you will need to have an awareness of their impact when providing advice to clients on any proposed restructures. In this paper, the following issues are presented in a practical format, with case studies to demonstrate the issues:

  • the perceived mischief – is the taxpayer’s purpose relevant?
  • tax benefits – tax effects v non-tax effects
  • the new paradigm for counterfactuals
  • possible application of Part IVA to very simple transactions (this was never meant to happen!).

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Author Photo - David MARSCHKE
David MARSCHKE

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This was presented at SME Structures - Avoiding a Train Wreck .

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Part IVA and restructures

Author(s):  David MARSCHKE

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