The latest Part of AT Rev includes the following articles: “Judicial construction of Part IVA: What to expect from the application of existing principles going forward” – Justice Richard Edmonds; “The 2013 Part IVA “reforms”” – A H Slater QC; “The new “improved” Part IVA – with extra tax benefit!” – Gordon Cooper and Tim Russell; “Taxation by analogy” – Graeme S Cooper; “The GAAR panels in Australia and the UK: Identical twins or distant cousins?” – Ann O’Connell; and “When is avoiding tax not abusive? Comparative approaches to a GAAR in Australia and the United Kingdom” – Malcolm Gammie CBE QC.
The second Part of Volume 41 of the Australian Tax Review includes an article by Tim Russell discussing the commercial motivations underpinning the choice of foreign private equity investment structures and an article by Sylvia Villios, Domenic Carbone, John Tretola and Pasqualina Callea analysing the capital gains tax implications of buy-sell agreements. There is also an editorial looking at tax law change and a review of “Tax Polymath: A Life in International Taxation – Essays in Honour of John F Avery Jones”.
The latest issue of the Australian Tax Review includes three articles on various aspects of Australian tax law, including the imposition of Australian tax on capital gains derived by non-resident taxpayers, the worldwide changes that have taken place in relation to transfer pricing regulation and enforcement, and the legislative origin of present entitlement in Australia. As this Part is the last in the volume it also includes an editorial on the politics and practicalities of tax in 2011.