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Beware 47A!

Published on 01 Apr 07 by "THE TAX SPECIALIST" JOURNAL ARTICLE

Section 47A is an anti-avoidance provision that deems certain benefits provided by Controlled Foreign Companies to other entities to be dividends. The ATO has recently released Draft Taxation Determination TD 2007/D1 which outlines the application of section 47A to situations where a CFC provides these covered benefits to another associated CFC. This article analyses the ATO’s reasoning and conclusions in the Draft Determination.

Author profile:

Dr Philip Bender
Philip is a Barrister and member of the Institute of Chartered Accountants practising in State and Federal taxation, superannuation and commercial law. He is also a sessional member of the Victorian Civil and Administrative Tribunal (although he still appears as a barrister in the tax list of that Tribunal). Philip advises and appears for taxpayers and revenue authorities in State and Federal courts and tribunals and has appeared on a number of occasions in the High Court. He has also been briefed by other government agencies including ASIC, the Official Trustee in Bankruptcy and the Victorian Government Solicitor's Office. Current at 01 October 2014 Click here to expand/collapse more articles by Philip BENDER.
 
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