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You have recently commenced work for the Australian taxation division of YE International LLP an international accounting partnership. A partner in the Houston Texas office
You have recently commenced work for the Australian taxation division of YE International LLP an international accounting partnership. A partner in the Houston Texas office has contacted you and stated that one of his clients has a partly owned subsidiary in Australia that has asked him questions about four Australian Tax law cases, and accordingly he has told them that he would obtain an analysis of the cases. He is accordingly requesting you to provide the analysis for him to pass to the client. The cases are: 1stTax Case:SNF (Australia) Pty Ltd v FC of T(2011) 193 FCR 149 2ndTax Case:Resource Capital Fund IV LP v Commissioner of Taxation[2019] FCAFC 51 3rdTax Case:Burton v Commissioner of Taxation[2019] FCAFC 141. 4thTax Case:Chevron Australia Holdings Pty Ltd (CAHPL) v Commissioner of Taxation [2017] FCAFC 62 In providing your analysis, the following 5 points must be addressed: 1stThe arguments and Facts of the case. 2ndWhat did the taxpayer say? 3rdWhat was the main issue? 4thWhat was the Commissioner's argument? 5thWhat did the Judges say? In your answer refer to Legislation, ATO and OECD Material
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