DIS on CoT v Guardian – Full Federal Court applied Part IVA but confirmed s100A did not apply (but it might in other circumstances)

On 24.4.23, the ATO issued a ‘Decision Impact Statement‘ on the effect of the Full Federal Court case of CofT v Guardian AIT Pty Ltd atf Australian Investment Trust [2023] FCAFC 3. This appeal was watched closely, as it involved the ‘Trust Stripping’ anti-avoidance provision” s100A of the ITAA36, which is rarely litigated. At first instance…

Tax Month – April 2023

T a x  T e c h n i c a l  –  M o n t h l y  N e w s – April 2023 Edition – ‘Tax Developments’ for tax practitioners by a tax practitioner.   Compiled by F John Morgan A member of the Victorian Bar (www.FJMtax.com) Table of Contents ______________________________________________________________________________ COMPILING…