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Begging for mercy - Practitioner and ATO experience with Division 7A discretion presentation

Published on 03 May 12 by SOUTH AUSTRALIAN DIVISION, THE TAX INSTITUTE

This presentation covers:

  • overview of Section 109RB
  • administrative law principles
  • does Division 7A apply?
  • conditions
  • administrative review.

Author profiles

Mathew Umina
Mathew is an Assistant Commissioner in the Public Groups & International area of the ATO. Mathew has been with the ATO for more than 15 years and has held several senior roles in corporate tax and international areas, as well as the SME and high wealth individuals area. This has included several years working on the design and implementation of the TOFA regime, and more recently as the ATO delegate and Competent Authority to the JITSIC Taskforce in London. Mathew is currently responsible for the ATO's Energy and Resources Industry Strategy, as well as a Competent Authority for mutual agreement procedure and advance pricing agreements casework. Mathew also works in the Technical Resolution area, working on complex and strategically significant cases in the Public Groups market. - Current at 30 April 2015
Andrew Sinclair CTA
Andrew Sinclair, CTA is a partner in Cowell Clarke's Tax & Revenue practice group. As a tax and superannuation specialist with over 25 years' experience, his qualifications are in law and as a Chartered Accountant. With a broad knowledge of corporate and business law, Andrew has specialist expertise in private client scenarios. This usually involves discretionary trusts, private companies and the diversity of views that family dynamics delivers. - Current at 22 November 2017
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This was presented at 45th South Australian Convention .

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Individual sessions


Begging for mercy - Practitioner and ATO experience with Division 7A discretion

Author(s):  Andrew SINCLAIR,  Mathew UMINA

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