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Sue is a partner in the Dispute Resolution and Litigation team with more than 30 years’ experience in federal and state tax risk and dispute management including:

  • tax audits
  • alternative dispute resolution (ADR)
  • tax litigation
  • Australian Tax Office (ATO) powers in relation to access to premises and production of documents
  • ATO anti-avoidance powers.

Sue is recognised for combining technical and strategic advice to provide certainty on tax issues. She works with clients to avoid disputes by ensuring evidence is available to support positions and, where necessary, engaging with the ATO to agree tax outcomes. Where disputes arise, Sue’s extensive experience in ADR and settlement negotiations against the ATO, Innovation Australia and other revenue authorities provides a strong platform for successful outcomes. 

Sue is an accredited mediator, a lecturer in the Master of Laws program at University of Melbourne, a member of the Commissioner of Taxation’s Remedial Powers Panel and a former president of the Tax Institute. 

Sue has been listed in The Best Lawyers in Australia since 2012 for Tax Law. In 2022, Doyle's Guide recognised Sue as a recommended taxation lawyer.


Sue’s recent experience includes: 

  • advising on film tax offsets, including producer offset
  • advising public entities, high-net-worth individuals, private groups, and not-for-profits on federal and state tax risk management including rulings, reviews, audits, ADR and litigation
  • assessing tax risks and advising on appropriate risk management approaches including tax corporate governance to reduce the risk of tax disputes
  • working with clients to manage risk by ensuring they have evidence to support tax positions
  • initiating and facilitating ATO engagement to achieve tax certainty and manage risk including obtaining private rulings in relation to income tax and GST matters
  • providing second and/or independent opinions on key tax risk issues to assist in risk management decisions and decisions relating to disclosure in accounts or to the market
  • advising on all stages of ATO audits and reviews including evidence gathering, assessment of risk and negotiating resolution of the audits and reviews
  • managing penalty and interest exposure including voluntary disclosures
  • managing ADR matters including early neutral evaluation and ATO in-house facilitation
  • advising clients on ATO power to access documents including claims for legal professional privilege
  • advising clients on ATO debt recovery matters including ATO garnishee notices
  • more recent disputes Sue has advised have involved transfer pricing, capital gains tax, hybrids, research and development tax concession, rental property deductions, land tax and stamp duty
  • participation in various industry and government committees and consulted with Treasury and the ATO on taxation issues.


31 May 2023 - Knowledge

Constitutional challenge: Can states tax electric cars?

#Planning, Environment & Sustainability, #Taxation

A landmark case before the High Court will determine the constitutional validity of Victoria’s recent electric vehicle tax.

30 May 2023 - Knowledge

Victorian state budget 2023-24 – taxing changes to land tax, payroll tax & stamp duty

#Taxation, #Property, Planning & Development

The COVID debt levy introduced in the 2023-24 Victorian state budget comes with significant changes to land tax, payroll tax and stamp duty. We summarise the key measures and who will be impacted.

24 May 2023 - Knowledge

Taxpayer alert – ATO to crack down on landlords, short-term rentals and WFH deductions


The Federal Government has announced significant funding to extend ATO compliance programs targeted at landlords, remote employees, home-based businesses, and to scrutinise both income and deductions from short-term rentals. This article higlights the ATO’s key focus areas and reminds taxpayers about the need to maintain proper records to substantiate any tax returns in the event of an audit or investigation.

12 January 2023 - Knowledge

Court limits ability for taxpayers to challenge the validity of formal ATO notices


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.

22 June 2022 - Knowledge

The ATO is knocking: Tax tips for you and your business


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.

14 December 2021 - Knowledge

Next 5000 Findings Report identifies key errors common to many private groups


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.