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Part IVA - Analysis and statutory construction presentation

Published on 23 Oct 13 by NEW SOUTH WALES DIVISION, THE TAX INSTITUTE

This presentation covers:

  • the new tax benefit test
  • annihilation versus reconstruction
  • has the relationship between the 3 elements changed
  • the do nothing defence
  • the evidentiary process
  • the EM and its role.

Author profiles:

Eddy Moussa CTA
Eddy is a practising Tax Lawyer who has extensive experience in providing taxation advice on financing, international and domestic structuring, and merger and acquisition transactions. He has advised a number of multinational organisations on international tax issues including cash repatriation, investment structuring, withholding tax and treaty issues. He has also led and project managed numerous tax compliance projects for local and multinational businesses in various industries. Eddy has experience in providing tax risk management advice and “health check” assignments for large multinational clients. Current at 01 February 2016 Click here to expand/collapse more articles by Eddy MOUSSA.
 
Harish Ekambareshwar
Harish is a Senior Solicitor at PwC. Current at 23 October 2013 Click here to expand/collapse more articles by Harish EKAMBARESHWAR.

Caleb Khoo
Caleb is a Senior Associate at PwC. Current at 23 October 2013

This was presented at Corporate Tax Masterclass.

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