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Treaty shopping & Part IVA

Published on 27 Feb 98 by VICTORIAN DIVISION, THE TAX INSTITUTE

- can you afford to go treaty shopping?
- does Part IVA apply?
- some observations from Lamesa

Author profile:

Hon Ian Vitaly Gzell AM QC FTI-Life
Mr Gzell was admitted to the Queensland Bar in 1965 and was appointed Queen's Counsel in 1977. He sat on the Equity Division of the Supreme Court of New South Wales from 2002 until his retirement in 2013. Apart from his other duties, he was the Revenue List Judge. He was admitted as a Barrister in every state and territory of Australia and in New Zealand and Papua New Guinea, with admissions for multiple single causes in Singapore, Fiji and the Solomon Islands. At the Bar, Mr Gzell specialised in revenue law with particular emphasis on international taxation. He was President of The Tax Institute from 1985-1986 and President of the Commercial Law Association of Australia from 1994-1996. He was Chairman of the Society of Trust and Estate Practitioners Australia and of its New South Wales branch from 2007-2013. He was a Council Member of the Society World Wide from 2011-2013. In 2012 Mr Gzell was appointed President of The International Academy of Estate and Trust Law. He has had numerous articles published and is in constant demand as a speaker. Current at 16 February 2015 Click here to expand/collapse more articles by The Hon. Justice Ian GZELL.
 

This was presented at Red Series: International Tax Masterclass.

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Individual sessions

Transferor Trusts

Author(s):  Richard SHADDICK

Materials from this session:

Permanent Establishments: Common & Topical Issues

Author(s):  Tim COX

Materials from this session:

Treaty Shopping & Part IVA

Author(s):  The Hon. Justice Ian GZELL

Materials from this session:

Application of business profits articles to CGT

Author(s):  Jason CHANG

Materials from this session:

Impact of 1997 legislative changes

Author(s):  Zorach DISKIN

Materials from this session:

Royalty WHT Issues and DTAS

Author(s):  Chris BIRCHALL

Materials from this session:

Cross border leasing

Author(s):  Charles ARMITAGE

Materials from this session:

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