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Division 6C of the ITAA36 negative control paper


This paper covers:

  • Division 6C
  • principles of statutory construction
  • legislative history
  • ATO view
  • negative Control and s 102N(1)(b)
  • Where to from here?

Author profiles

Terry Murphy QC, CTA
Terry has focused on advising and appearing for taxpayer and revenue authorities in the Federal Court and High Court, and in alternative dispute resolution for over 30 years. He was appointed to be the Special Counsel to the Australian Taxation Office from 2008 to 2010 and was a Past President of the Tax Bar Association. Terry is a member of Taxation Subcommittee of the Law Council, Chair of the Tax Group Advisory Board, and a Senior Fellow of the University of Melbourne Law School. - Current at 30 August 2021
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Dr Dr. Julianne Jaques CTA
Julianne is a barrister specialising in taxation law and regularly appears in taxation matters in the AAT and Federal courts, including more recently in the cases of Sharpcan, Victoria Power Networks and Sole Luna. Prior to coming to the Bar, Julianne spent 10 years in private practice with a major accounting firm and a major law firm, and was senior taxation adviser to the Federal Assistant Treasurer. She is a Chartered Tax Adviser and a Chartered Accountant, and her doctoral thesis at the University of Melbourne was on the taxation of corporates. Julianne is a member of the Tax Practitioners Board and the Board of Taxation. In 2020, Julianne was awarded Chartered Tax Adviser of the Year by The Tax Institute. - Current at 16 August 2021
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This was presented at National Infrastructure Conference .

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Individual sessions

Division 6C of the ITAA36 negative control

Author(s):  Terry MURPHY,  Julianne JAQUES

Materials from this session:

Division 6C property funds - Land in the context of infrastructure

Author(s):  Chris PEADON

Materials from this session:

Tax sharing and tax funding agreements in a project financing context

Author(s):  David WOOD

Materials from this session:

ATO areas of compliance focus

Author(s):  Rhys MANLEY,  Craig SAUNDERS

Materials from this session:

The infrastructure market in Australia current themes and perspectives

Author(s):  John Pickhaver

Materials from this session:

Further details about this event:


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