Part IVA of the Income Tax Assessment Act after Spotless - a brave new world?

The Australian High Court's 1996 decision in Commissioner of Taxation v. Spotless Services calls into questions the reach of the Income Tax Assessment Act's part 4A in regards to anti-tax avoidance schemes. The court interpreted part 4A literally and rejected the 'choice principle' concept. Under this decision, taxpayers can no longer obtain tax benefits if they arrange their affairs with tax benefits as the dominant purpose.