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There is a world of difference in tax law. s.51AAA ITAA36. Cheers, Rob

Andrew gets mis-quoted or 'selectively quoted' quite a bit because he is prepared to stick his neck out as a spokesperson for a part of the tax compliance industry. 16,000 pages of vague, inconsistent & unsettled legislation is bound to add a bit of stress to any tax adviser's job. Cheers...

Nope. What's more ... the ATO is still not having a great time in court with this provision. People are getting scared because they think it is subjective intention that matters. Courts don't want to know what is in your head. The courts have always stressed objective intention ...