Forming an opinion of ‘fraud or evasion’ – is this the Commissioner’s unchallengeable right to an unlimited amendment period?

05 May 2017 Topics: Tax and revenue, Tax disputes

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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