Published on 01 Nov 07
by VICTORIAN DIVISION, THE TAX INSTITUTE
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.
Carmen is Head of the national Tax Controversy team at Maddocks. She has specialist expertise in the conduct of tax controversy associated with the general anti-avoidance provisions of the Income Tax Assessment Act, transfer pricing, GST and all other areas of taxation on behalf of large corporates. She is also responsible for the management and conduct of tax litigation on behalf of the Australian Tax Office (ATO) including managing early disputes and alternative dispute resolution processes for the ATO. Carmen also conducts tax litigation on behalf of large corporates.
- Current at
13 October 2016