Published on 01 Nov 07
by "AUSTRALIAN TAX FORUM" JOURNAL ARTICLE
This presentation covers:
1. Protecting your client's privileged documents:
- What does legal professional privilege mean?
- What is subject to legal professional privilege and what isn't?
- What should you do to protect legal professional privilege?
- Can there be limited waiver of legal professional privilege if you do disclose?
- Dangers of disclosing legal advice so as to run a RAP argument
2. ATO access to accountants workpapers and advice:
- What do the ATO Guidelines say?
- How much protection do they really offer?
- What the courts have said
- What should you do when asked by the ATO to provide your advice and workpapers?
- ALRC recommendation to make accountants tax advice privileged.
Ashley is a Partner in the Tax Controversy team at PwC. He focusses on strategic resolution of tax disputes. Ashley has over 25 years tax experience including 20 years with the ATO. Ashley was one of the youngest tax officers to have been promoted to assistant commissioner in the ATO in 2001, and was senior assistant commissioner for Large Business and International Tax division when he left the ATO to join PwC in 2007. Ashley recognises that attempting to resolve tax disputes comes with its technical complexities. By combining his extensive ATO experience and his insight into contemporary ADR processes, Ashley has been instrumental in advising many clients in negotiating complex tax dispute settlements. He has also successfully assisted many clients in defending their tax positions, including through obtaining positive ATO rulings.
- Current at
29 October 2014