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and I guess that's the scary part. Agreed though I have to say that this type of structure is what I would call an advanced technique. I would think that someone advanced enough to employ it would also be aware of the implication of invalid reasons for doing so. Not being armed with enough...

Please explain? But who would actually do that? Someone who's only intent is tax avoidance? and therefore Part IVA should kick them in the pants.... I see it as perfectly legitimate to capitalise interest when the obvious way to service the necessary debt is via this method. Many...