We provide strategic, technical and pragmatic solutions to help clients manage the tax risk process including guidance to avoid tax disputes and, where necessary, management of federal and state tax disputes.
We bring together our expert knowledge of tax and our expertise in dispute management to focus on everything needed to strengthen your position for early resolution or, where necessary, taking the matter through the Courts.
Our team of experienced practitioners are committed to working together to secure the best outcomes for our clients, with particular expertise in:
The Tax Hub is a resource bank where we bring together our expert knowledge of tax and our expertise in dispute management to focus on everything needed to strengthen your position for early resolution or, where necessary, taking the matter through the Courts. View the Tax Hub.
In addition to the reported tax cases listed below our team has been involved in a number of significant unreported matters including:
Team members have been involved in the conduct of the following reported cases, including key cases involving the Commissioner of Taxation (FCT), in the last 10 years:
01 March 2023 - Knowledge
The Full Federal Court has rejected the Commissioner of Taxation’s appeal on section 100A from the first decision in the Guardian AIT case, confirming that the inquiry required by section 100A is different to Part IVA of the Income Tax Assessment Act.
19 January 2023 - Knowledge
#Taxation, #Superannuation, Funds Management & Financial Services
Revenue authorities are increasing their scrutiny of industries with independent contractors being engaged – from university lecturers to delivery drivers. This article looks at the relationships between mortgage aggregators and their independent contractor arrangements with mortgage brokers. Direct parallels can probably be drawn with the insurance industry and share trading brokers.
12 January 2023 - Knowledge
Preparing early and seeking legal advice when responding to formal ATO information requests is important for taxpayers to be aware of when managing tax disputes and the ATO relationship.
30 November 2022 - Knowledge
The Government has released the Treasury Laws Amendment (Measures for a later sitting) Bill 2022: Franked distributions funded by capital raisings. If enacted, franking credits will not be available for distributions made since 19 December 2016 that are funded by capital if they made outside of ordinary distribution patterns.
29 June 2022 - Knowledge
#Taxation, #Corporate Restructuring and Insolvency
In this first instalment of a two-part series on the ATO’s debt collection efforts, we look at two ‘awareness letters’ taxpayers are receiving from the ATO and the penalties for unpaid tax liabilities.
22 June 2022 - Knowledge
With the financial year coming to a close, we know how frantic this time of year can be personally, and from a business perspective. In this article, we highlight the key tax considerations to be aware of to put you and your business in the best possible position come 30 June.
09 March 2022 - Knowledge
#Dispute Resolution & Litigation, #Taxation
A recent Federal Court decision has demonstrated that the Commissioner of Taxation can seek freezing orders to enforce tax debts against overseas parties.
07 March 2022 - Knowledge
When dealing with tax reviews and tax audits, it is important to adopt a proactive approach in your response to the ATO to ensure that the information requested is provided in a timely manner.
25 February 2022 - Knowledge
The ATO’s new draft taxation determination, TD 2022/D1, signals a shift away from sub-trusts as a means to comply with Division 7A of the Income Tax Assessment Act 1936. How will this impact trust distributions?
02 February 2022 - Knowledge
#Taxation, #Dispute Resolution & Litigation
With the ATO’s guidance on section 100A of the Income Tax Assessment Act 1936 rumoured to be imminently released, the Federal Court’s recent decision in Guardian AIT Pty Ltd ATF Australian Investment Trust v Commissioner of Taxation  FCA 1619 is of compelling interest to tax professionals across the country.
14 December 2021 - Knowledge
Private groups need to prepare for their Next 5,000 reviews by implementing documented tax governance and reviewing key focus areas to validate positions, including Division 7A arrangements and that trusts have made valid distribution resolutions.
13 December 2021 - Knowledge
We review the current tax residency tests for individuals and discuss how a proposed new framework may change the landscape.