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The shifting Part IVA landscape paper

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Unless expressly stated, opinions are not that of The Tax Institute, which accepts no responsibility for the accuracy of any of the information contained within it.

Published on 13 Feb 13 by NATIONAL DIVISION, THE TAX INSTITUTE

A series of ATO losses in Part IVA cases prompted the recent changes to Part IVA. What are the significant features of the changes and what new issues arise? The changes are intended to improve the “effectiveness” of Part IVA – but to what extent do the changes achieve that goal? How would the cases that the ATO lost be decided under the new rules?

Author profiles

Lawrence Magid CTA
Larry has been a Tax Partner at Allens for over 30 years. He specialises in corporate and international taxation including, in particular, financing issues, capital raising and company distributions. He has represented the Law Council of Australia in consultations with government on Part IVA (as well as on the NTLG Finance & Investment Subcommittee) and was a member of the Roundtable which advised Treasury on the amendments made to Part IVA in 2013. He was also a member of the Board of Taxation working group which conducted the post-implementation review of Div 974. - Current at 08 March 2016
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James Pettigrew ATI
James is a Partner in the Sydney office of Deloitte. He advises on a wide range of corporate tax matters for clients primarily in the finance, infrastructure, property and funds management sectors. He has presented for the Tax Institute and the Institute of Chartered Accountants in Australia, and he has lectured in the University of Sydney Masters Degree Programme. - Current at 06 February 2014
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This was presented at 2013 Financial Services Tax Conference .

Get a 20% discount when you buy all the items from this event.

Individual sessions

Topical tax treaty issues for the financial sector

Author(s):  Richard J VANN

Materials from this session:

The attribution of income, losses and outgoings to foreign permanent establishments of Australian banks

Author(s):  Ian FULLERTON

Materials from this session:

Transfer pricing and funds management

Author(s):  Damian PRESHAW

Materials from this session:

Emerging regional issues (funds management)

Author(s):  Daryl CHOO,  Brian CHAMBERS

Materials from this session:

The shifting Part IVA landscape

Author(s):  Larry MAGID,  James PETTIGREW

Materials from this session:

Australian Taxation Office audits, risk identification, dispute

Author(s):  Ashley KING,  Andrew MCLOUGHLIN

Materials from this session:

GST and RITCs on trustee services

Author(s):  Amelia O'Rourke,  Bill PACKWOOD

Materials from this session:

Losses

Author(s):  Julian HUMPHREY

Materials from this session:

Capital management of financial institutions and the related tax issues

Author(s):  Tricia HO-HUDSON

Materials from this session:

The Rubik's Cube of tax - An update on trusts

Author(s):  Andrew MILLS,  Matt HARTSHORN

Materials from this session:

New R&D regime in financial services

Author(s):  Jamie MUNDY

Materials from this session:

The promoter penalty regime - How the ATO ia applying it in practice

Author(s):  Bruce COLLINS,  Nathan FIRTH

Materials from this session:

TOFA - A new world of economic substance?

Author(s):  Phillip COLE

Materials from this session:

Income tax case update

Author(s):  Cameron RIDER

Materials from this session:

Asset financing/thin capitalisation/infrastructure update

Author(s):  Steve FORD,  Arash AZIMI

Materials from this session:

MRRT and Carbon Tax: Issues for financiers and funds

Author(s):  Teresa DYSON

Materials from this session:

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