You have been invited by the local group of Tax Agents of which you are a member to discuss at the next meeting of the group the decision in Commissioner of Taxation v SNF (Australia) Pty Ltd, High Court of Australia, 1st June 2011 which was the outcome of an appeal by the Commissioner to the Full Federal Court against a decision in the Federal Court that the commissioner had misapplied sec 136AA and 136 AD of the ITAA1936.

Required:

Prepare a brief paper (in academic style) for presentation to the group covering the following points:

1. a full explanation of why this particular case reached the high court
2. a critical analysis of the tax law principles on which the taxpayer’s arguments were based
3. a critical analysis of the Commissioners arguments in reaching their decision
4. what principles from other tax law cases did the judges refer to in supporting and making their decision?