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Understanding the new Part IVA paper


This paper covers:

  • development of jurisprudence on Part IVA
  • dominant purpose
  • changes to the 'Reasonable Expectation Test' 
  • framing and proving the alternative postulate
  • exclusion of Assessable Income Tax Benefit - The 'Do Nothing' Alternative Postulate 
  • allowable Deduction Tax Benefit – Alternative Postulate 
  • the Commissioner's Grievances with the Alternative Postulate
  • policy
  • basis of amendment to 'reasonable expectation test'
  • Assistant Treasurer’s Announcement - November 2012 and 2013 Amendments
  • Government’s concerns and policy response 
  • key amendments and concepts contained in the 2013 Bill.

Author profile

William Thompson CTA
Bill works for Minter Ellison as Tax Practice Head and Managing Partner of the firm's Brisbane office. Bill is a past National Chair of the Taxation Committee Law Council of Australia, a past Chair of the Taxation Institute of Australia, Queensland Division and has been an executive officer of the Taxes Section of the International Bar Association. Bill advises Australian and international clients in structuring and transactional tax matters, and has particular experience in taxation disputes including litigation to appellate level in the Federal and Queensland jurisdictions. He is well known as a presenter on tax issues in Australia and has been an invited speaker for tax conferences of the IBA, the American Bar Association Tax Committee (Foreign Lawyers) and the Taxation Academy of Singapore. - Current at 02 July 2012
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Understanding the new Part IVA

Author(s):  William (Bill) D THOMPSON

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