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Part IVA and private business advisers

Published on 01 Jul 14 by "TAXATION IN AUSTRALIA" JOURNAL ARTICLE

This article aims to provide a practical understanding of how Pt IVA would have application to an arrangement, and a path to explain Pt IVA to would-be adversaries as well as clients. The article sets out to clarify that, despite a taxpayer’s subjective purpose, purpose as referenced in Pt IVA is unrelated and does not take into consideration the client’s subjective purposes or any other. For advisers, there needs to be an alignment between the two so that the adviser can comfortably address Pt IVA when advising clients.

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John Ioannou

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