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Part IVA presentation

Published on 21 Nov 08 by NATIONAL DIVISION, THE TAX INSTITUTE

This presentation covers:

  • does structuring for access to Div 152 constitute a Part IVA scheme?
  • when does the making of a choice/election not give rise to a tax benefit?
  • what does the exclusion in s.177C(2) really mean in light of Walter's Case?
  • does use of the GVSR 4 year reversal constitute a scheme?
  • when does legitimate restructuring become scheme promotion - re: Keenhilt Pty Ltd as Trustee for the CHC Services Trust v FCT?

Author profile

Andrew Sinclair CTA
Andrew Sinclair, CTA is a partner in Cowell Clarke's Tax & Revenue practice group. As a tax and superannuation specialist with over 25 years' experience, his qualifications are in law and as a Chartered Accountant. With a broad knowledge of corporate and business law, Andrew has specialist expertise in private client scenarios. This usually involves discretionary trusts, private companies and the diversity of views that family dynamics delivers. - Current at 22 November 2017
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This was presented at Conquering CGT .

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