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The application of Part IVA to stapled structures paper


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
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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
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This was presented at 2018 National Infrastructure Conference .

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Author(s):  Jeremy HIRSCHHORN

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

Author(s):  Sharon Murray

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Valuations: Key legal principles and recent case law

Author(s):  Julia Fry,  Cameron RIDER

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