Herbert Smith Freehills Podcasts Herbert Smith Freehills Podcasts
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- Business
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A series of thought leading podcasts ranging on topics and sectors by Herbert Smith Freehills. For more information please visit www.herbertsmithfreehills.com
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Tax Bites EP11: Navigating Australia's Tax Landscape: A discussion on recent Part IVA Decisions
In this episode of the Herbert Smith Freehills Tax Bites podcast, Toby Eggleston partners with Consulting Professor Graham Cooper and fellow partner Ryan Leslie to dive deep into recent Federal Court decisions on the anti-avoidance provisions in Part IVA of the Income Tax Assessment Act 1936. The discussion begins with insights into the Minerva Financial Group vs. Commissioner of Taxation, highlighting the saga of restructuring for an IPO and the accompanying tax implications. Also explored is the Mylan Australia Holdings case involving a debt push down strategy and the ATO’s application of Part IVA. The episode touches on pivotal aspects such as the significance of counterfactual scenarios, determination of tax benefits, and the overarching question of dominant purpose in context to Part IVA. The conversation also delves into the potential implications of the 2012 amendments compared to the pre-amendment rulings and foreshadows the impact of recent budget announcements on future tax avoidance disputes.
00:00 Welcome to the Tax Bites Podcast
00:32 Deep Dive into Part IVA Decisions: Minerva Financial Group Case
14:04 Exploring the Mylan Australia Holdings Case: A Debt Push Down Analysis
30:01 Impact of 2012 and 2023 Part IVA Amendments on Tax Law
40:33 Final Thoughts and Future Directions in Tax Law
Want to go deeper? Read our tax notes on the cases
https://hsfnotes.com/taxaustralia/2024/03/12/minerva-financial-group-pty-ltd-v-commissioner-of-taxation/
https://hsfnotes.com/taxaustralia/2024/03/21/mylan-tax-note/ -
Himalayan Bites: EP26 Q1 2024 Wrap
Tony Damian and Andrew Rich are back! Himalayan Bites kicks off with our Q1 2024 review.
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FSR GPS (Australia): EP12 – ASIC V RM Capital
Join Partners Michael Vrisakis and Andrew Eastwood and solicitor Abby Sutherland in conversation on reasonable steps obligations and conflicted remuneration, as illuminated in the recent case of Australian Securities and Investments Commission v R M Capital Pty Ltd [2024] FCA 151.
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The Third Wheel (ESG Australia) EP41: So you want to be a carbon farmer?
Lucy McCullagh, Alice Molan, Mark Hatfull and Naomi Hutchings delve into the multifaceted world of carbon offset projects working toward Australia’s net zero and nature positive goals, from regulatory considerations to project finance and structuring. Key concepts are outlined including the Carbon Farming Initiative Act, the Australian Carbon Credit Unit (ACCU) scheme and the need to comply with financial services laws. They anticipate continued growth in the offset market driven by domestic and international players, the rise of joint ventures and debt financing, whilst acknowledging integrity issues and the importance of significant collaboration and partnerships.
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FSR GPS (Australia): EP11 – Important privilege implications from ASIC v Noumi Ltd
Andrew Eastwood and Bryony Adams discuss an important Federal Court judgment handed down recently in ASIC v Noumi Ltd which has wide-ranging implications for organisations facing litigation and regulatory proceedings and their approach to legal professional privilege, particularly those in the banking and financial services sectors.
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LPP: Legal Privilege Podcast (Aus) EP7 – Important privilege implications from ASIC v Noumi Ltd
Andrew Eastwood and Bryony Adams discuss an important Federal Court judgment handed down recently in ASIC v Noumi Ltd which has wide-ranging implications for organisations facing litigation and regulatory proceedings and their approach to legal professional privilege, particularly those in the banking and financial services sectors.
Customer Reviews
Global M&A trends
Great insight.
Brexit
It is an excellent initiative from HSF to put online Podcasts about Brexit.