Forming an opinion of fraud or evasion – is this the unchallengeable right to an unlimited amendment period for the ATO Commissioner?

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Cooper Grace Ward

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Established in 1980, Cooper Grace Ward is a leading independent law firm in Brisbane with over 20 partners and 200 team members. They offer a wide range of commercial legal services with a focus on corporate, commercial, property, litigation, insurance, tax, and family law. Their specialized team works across various industries, providing exceptional client service and fostering a strong team culture.
This article examines some recent Federal Court cases and comments on potential implications for the current tax regime.
Australia Tax

Recent Federal Court decisions have cast doubt on the ability of some taxpayers to have the Commissioner's opinion of fraud or evasion effectively reviewed. This potentially opens up an unlimited period of review for the Commissioner. This article briefly examines these cases and comments on the potential implications of the current regime.

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