There have been numerous significant court cases concerning Part IVA in recent years and the number of decisions shows no sign of abating. A number of these cases are producing outcomes that tax professionals might not have anticipated. This paper also includes the latest analysis of the Full Court of the Federal Court decision in Macquarie Finance Limited. Justice Edmonds is eminently qualified to speak on Part IVA and Division 165. He is one of Australia's foremost taxation authorities including Harts case. His presentation will include:
- overview and comparison of general anti-avoidance provisions in the ITAA and GST Acts
- particular issues to be learnt from the cases in arguing for or against the application of general anti-avoidance provisions
- interrelationship between general and specific anti-avoidance provisions
- interrelationship of tax benefit with choices, elections, declarations and agreements
- analysis of Macquarie Finance Limited.