From ordinary to anti-avoidance: the power of Part IVA

from Tax Archives with Fletch and Sarah · host HLS Tax Law

Let’s talk about Part IVA — where is the line between tax avoidance and ordinary tax planning? In this episode, Fletch and Sarah break down the elements of Part IVA, current risks and lessons from recent cases.

What this episode covers

Let’s talk about Part IVA — the provision that can turn an otherwise ordinary arrangement into a full-blown anti-avoidance drama. In this episode, Fletch and Sarah break down why Part IVA keeps popping up in audits, how the counterfactual shapes the outcome, and the classic mistakes that land taxpayers in hot water. Plus, they share lessons from recent cases that show Part IVA is never as straightforward as it looks.

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From ordinary to anti-avoidance: the power of Part IVA

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How long is this episode of Tax Archives with Fletch and Sarah?

This episode is 35 minutes long.

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This episode was published on November 25, 2025.

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Yes, a full transcript is available for this episode. You can read the complete transcript on the episode page.

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