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: 1st Tax Case: SNF (Australia) Pty Ltd v FC of T (2011) 193 FCR 149 (10 Marks)

2nd Tax Case: Resource Capital Fund IV LP v Commissioner of Taxation [2019] FCAFC 51 (10 Marks)

3rd Tax Case: Burton v Commissioner of Taxation [2019] FCAFC 141. (15 Marks)

4thTax Case: Chevron Australia Holdings Pty Ltd (CAHPL) v Commissioner of Taxation [2017] FCAFC 62

(15 Marks)

In providing your analysis, the following 5 points must be addressed:

1st The arguments and Facts of the case.

2nd What did the taxpayer say?

3rd What was the main issue?

4th What was the Commissioners argument?

5th What did the Judges say?

In your answer refer to Legislation, ATO and OECD Material.