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Part IVA and restructures paper


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!).

Author profile

David Marschke CTA
Photo of author, David MARSCHKE David is a Chartered Accountant, tax agent and admitted lawyer. He is a Partner in the Mills Oakley Private Advisory Practice based in Brisbane and previously was a Partner within the tax group of a national law firm. David is a specialist adviser to the private enterprise and to SME and high-wealth individuals sectors, with particular experience assisting taxpayers and their advisers in dispute matters, including tax reviews, audits and complex tax negotiations and settlements. He has significant expertise advising on SME, professional practice (including medical practices) and high-wealth individuals structuring and transactions with a focus on tax-effective outcomes, while understanding the potential application of the tax integrity measures including Part IVA. - Current at 12 April 2017
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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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