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:

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

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

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:

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

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

1^st The arguments and Facts of the case.

2^nd What did the taxpayer say?

3^rd What was the main issue?

4^th What was the Commissioners argument?

5^th What did the Judges say?