shopping_cart

Your shopping cart is empty

The application of Part IVA to stapled structures paper

Member Price: $57.00
Non Member Price: $75.00

DisclaimerThis material is copyright. Apart from any fair dealing for the purposes of private study, research, criticism or review, as permitted under the Copyright Act, no part may be reproduced by any process without written permission from The Tax Institute.
Unless expressly stated, opinions are not that of The Tax Institute, which accepts no responsibility for the accuracy of any of the information contained within it.

Published on 17 May 18 by VICTORIAN DIVISION, THE TAX INSTITUTE

This paper covers:

  • staple arrangements
  • consideration by the courts of schemes involving stapled securities
  • use of stapled securities for investment in infrastructure
  • commercial reasons for stapled structures
  • how might the Commissioner seek to apply Part IVA?
  • Application of Part IVA.

 

 

 

 

Author profiles

Gregory Davies CTA
Greg Davies QC, CTA, practises principally in taxation and revenue law, administrative law, commercial law, corporations law and equity and trusts. He has appeared in many long and complex matters in the Federal Court at trial and appellate levels as well as in the High Court. Greg appeared in the following High Court cases: ElecNet (Aust) Pty Ltd v FCT, FCT v Sun Alliance Investments Pty Ltd, FCT v McNeil, FCT v Scully and FCT v Consolidated Press Holdings Ltd. He also appeared in leading Part IVA cases in the Full Federal Court, including AXA Asia Pacific Holdings Ltd v FCT, FCT v Lenzo, FCT v Ashwick, Puzey v FCT, FCT v Star City Ltd, Spassked Pty Ltd v FCT, Cumins v FCT, Pridecraft Pty Ltd v FCT and Eastern Nitrogen Ltd v FCT. - Current at 31 October 2019
Click here to expand/collapse more articles by Greg DAVIES.
Eugene Wheelahan QC FTI
Eugene Wheelahan QC, FTI, is a member of the Victorian Bar who practises principally in the area of tax. He has appeared for taxpayers and the Commissioner of Taxation in the Federal Court and the High Court. He acts for clients in the mining, infrastructure, telecommunications and financial services industries, among others, providing opinions and assisting them in their dealings with the Commissioner during reviews, audits, objections and litigation. Eugene has a Master of Tax from the University of Melbourne where he is a Senior Fellow of the Law Faculty, lecturing in the subjects Tax Litigation and Tax Avoidance and Planning. - Current at 15 June 2022
Click here to expand/collapse more articles by Eugene Wheelahan.

 

This was presented at 2018 National Infrastructure Conference .

Get a 20% discount when you buy all the items from this event.

Individual sessions

Key issues in structuring outbound investments

Author(s):  Edward Consett

Materials from this session:

The application of Part IVA to stapled structures

Author(s):  Greg DAVIES,  Eugene Wheelahan

Materials from this session:

Stamp duty issues in infrastructure transactions: What is land?

Author(s):  Katrina PARKYN

Materials from this session:

Privatisations effected by statutory vesting- Outside the scope of GST?

Author(s):  Tim Sinclair

Materials from this session:

Providing investor certainty tax deeds

Author(s):  Thomas Wu,  Michael CLOUGH

Materials from this session:

ATO reflections on its approach in the market – Key issues in the infrastructure sector

Author(s):  Jeremy HIRSCHHORN

Materials from this session:

Delivering investor certainty; ATO advice and guidance products – Investor certainty

Author(s):  Sharon Murray

Materials from this session:

Valuations: Key legal principles and recent case law

Author(s):  Julia Fry,  Cameron RIDER

Materials from this session:

Further details about this event:

 

Copyright Statement