Junior Ltd had a tax loss of $500,000 from previous years. On 1 July of the current income year, Mr. X buys all the shares in Junior Ltd upon advice from Tina. Tina then suggests that Mr. X transfers $500,000 income from his own family trust into Junior Ltd, which will reduce the trusts income to $5,000 and leaves Junior Ltd with a zero taxable income.

Required:

Critically evaluate Tinas suggestion with particular reference to ITAA1936 Part IVA and discuss whether Part IVA would apply.