Miscellaneous 2003

Part IVA Assessments: Can the Commissioner have his Cake and Eat it Too?

Source: The Tax Specialist Journal Article

Published Date: 1 Apr 2003

 
This article looks at the consequences that flow from the Commissioner's current administration practice of seeking to rely on more than one amended assessment when attacking the deductibility of payments made pursuant to so called Part IVA arrangements. It is concluded that a second amended assessment based on Part IVA can only be a valid assessment if the Commissioner concedes that the payment is otherwise deductible.

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