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The aggregation of transactions presentation

Published on 25 Jul 13 by NATIONAL DIVISION, THE TAX INSTITUTE

Harry Lakis will outline the courts’ analysis of aggregation by reference to the key cases, with Jim Richards providing an administrator’s perspective. These presentations provide a comparison of the aggregation provisions and the Revenue Offices’ approaches, including:

  • how the “transfer model” jurisdictions differ from the others
  • factors required to be considered
  • when evaluating the factors, whose perspective is most relevant?
  • the availability of discretions
  • direction in which case law is moving
  • the approach taken when evaluating the aggregation of interests that may comprise a “significant interest” in the landholder/land rich context.

Author profile

Brian Richards CTA
Brian of Richards Advisory has specialised in providing taxation advice to accounting and legal practitioners in respect of a wide range of business clients for approximately 40 years. His particular taxation specialty areas include business restructuring, intellectual property transactions, CGT issues and tax planning matters. As a taxation specialist, Brian has extensive academic and other lecturing experience. - Current at 12 April 2017
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This was presented at 13th Annual States' Taxation Conference .

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