PARTNERSHIP - limited partnership - certificate of registration of limited partnership - whether certificate conclusive evidence of formation of limited partnership - whether necessary for partnership to exist before registration - general law partnership
TAXATION - dividends - franking credits - debt and equity interests - whether debt interest or equity interest - whether financial benefit provided under scheme - whether effectively non-contingent obligation under scheme to provide financial benefit
TAXATION - administrative penalty - whether position of taxpayer reasonably arguable - whether it would be concluded that what is argued for is about as likely as not correct
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