The Commissioner may amend an assessment if he has formed the opinion that there was “fraud or evasion”.
In this paper, David W Marks, QC, CTA, points out that this can and does happen outside of the defined limitation periods, greatly raising the stakes for taxpayers under audit.
His paper looks at:
- The elements of “fraud or evasion”
- The taxpayer’s options when the Commissioner has formed such an opinion
- What the decided cases have said.
Access the paper by completing the form now.