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The shifting Part IVA landscape presentation


A series of ATO losses in Part IVA cases prompted the recent changes to Part IVA. What are the significant features of the changes and what new issues arise? The changes are intended to improve the “effectiveness” of Part IVA – but to what extent do the changes achieve that goal? How would the cases that the ATO lost be decided under the new rules?

Author profiles

Lawrence Magid CTA
Larry has been a Tax Partner at Allens for over 30 years. He specialises in corporate and international taxation including, in particular, financing issues, capital raising and company distributions. He has represented the Law Council of Australia in consultations with government on Part IVA (as well as on the NTLG Finance & Investment Subcommittee) and was a member of the Roundtable which advised Treasury on the amendments made to Part IVA in 2013. He was also a member of the Board of Taxation working group which conducted the post-implementation review of Div 974. - Current at 08 March 2016
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James Pettigrew ATI
James is a Partner in the Sydney office of Deloitte. He advises on a wide range of corporate tax matters for clients primarily in the finance, infrastructure, property and funds management sectors. He has presented for the Tax Institute and the Institute of Chartered Accountants in Australia, and he has lectured in the University of Sydney Masters Degree Programme. - Current at 06 February 2014
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This was presented at 2013 Financial Services Tax Conference .

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Individual sessions

Topical tax treaty issues for the financial sector

Author(s):  Richard J VANN

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Emerging regional issues (funds management)

Author(s):  Daryl CHOO,  Brian CHAMBERS

Materials from this session:

Australian Taxation Office audits, risk identification, dispute

Author(s):  Ashley KING,  Andrew MCLOUGHLIN

Materials from this session:

GST and RITCs on trustee services

Author(s):  Amelia O'Rourke,  Bill PACKWOOD

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New R&D regime in financial services

Author(s):  Jamie MUNDY

Materials from this session:

The promoter penalty regime - How the ATO ia applying it in practice

Author(s):  Bruce COLLINS,  Nathan FIRTH

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