Registration   |   8:00am - 8:30am
  Session 1:
  Opening address and President's welcome   |   8:30am - 9:00am

  Speaker: Marg Marshall, CTA, President, The Tax Institute

  Session 2:
  Justice Hill Memorial Lecture - The changing landscape of international tax: Hype and hope   |   9:00am - 10:00am

  Speaker: Graeme Cooper, FTI, Herbert Smith Freehills

  Morning tea   |   10:00am - 10:30am
Breakout sessions   |   10:30am - 11:30am
Session 3.1: The latest on Section 100A – Part 1

Speaker: Frank Hinoporos, CTA, Hall & Wilcox

The most-talked about issue in private markets tax in the last two years has been section 100A. In late 2022, following the Federal Court decisions in Guardian AIT and BBlood, the ATO finalised Taxation Ruling TR 2022/4 and Practical Compliance Guideline PCG 2022/2 that set out its interpretation of section 100A and reimbursement agreements. In 2023, the Full Federal Court handed down its decision from an appeal in Guardian AIT and a decision on the appeal in BBlood is pending. Revisions to TR 2022/4 and PCG 2022/2 are in the works.

This session will:

  • Explore the key legal principles established by Guardian AIT and BBlood with respect to section 100A, including what constitutes a ‘reimbursement agreement’, having a purpose of reducing tax and an ‘ordinary family or commercial dealing’ 
  • Discuss the broader practical considerations relevant to practitioners managing trust arrangements 
  • Contemplate issues that may potentially attract the attention of the ATO; and
  • Provide practical guidance on how taxpayers and their advisers can manage and mitigate their risk.
  Tax disputes
Session 3.2: The Commissioner’s powers to issue a tax assessment … What do I need to know?

Speaker: Kristie Schubert, CTA, KPMG Law

This session will explore:

  • Processes available for early engagement with the ATO
  • The Commissioner’s power to issue different kinds of assessments (deemed, default and special assessment)
  • Pros and cons of the different Part IVC review and appeal rights and other avenues such as Judicial Review
  • The limited amendment period, dealing with out of time objections and reviews
  • Evidence and information gathering (including expert evidence) to overcome the burden of proof in tax cases; and
  • Setting the grounds of dispute, the purpose of the SFIC, and “reasonableness” in cases such as Avon Downs, and Kolotex.
  Emerging leaders
Session 3.3: Australian tax for foreign residents

Speakers: Megan Bishop, Holding Redlich, Nik Sachdev, Holding Redlich

Various taxes at both a state and federal level are specifically targeted at non-Australian residents. When considering these taxes, regard must be had not only to the domestic legislation but also the interaction with various international agreements, including any relevant double tax agreements.

This session will:

  • Provide a foundational overview of the taxation of foreign residents in Australia, both with regard to inbound and outbound investment
  • Discuss the tests for determining residency
  • Consider key updates in this area over the past few years; and
  • Consider the interaction of double tax agreements with federal and state taxes.
Session 3.4: Lessons from Aurizon and what's on the horizon?

Speakers: Annabel Burnett, University of Cambridge, Chris Peadon, FTI, New Chambers

This session will look at the Aurizon Holdings Limited case which considered the meaning of share capital and the importance of contemporaneous documentation to support capital funding transactions. Also discussed are the impact of recent and proposed amendments to tax law in the area of capital management on corporate capital management strategies, including:

  • Off-market share buy-back rules for listed public companies
  • Frankable distributions funded by certain capital raising activity
  • The impact on the ability of companies to return funds to shareholders; and
  • How to obtain certainty on the tax outcomes for ‘out of cycle’ franked distributions.
Breakout sessions   |   11:30am - 12:30pm
Session 4.1: Practical application and implications of Section 100A - Part 2

Speakers: Leanne Connor, CTA, WGC Business Advisors, Fiona Dillon, CTA, Australian Taxation Office Robyn Jacobson, CTA, The Tax Institute

The ATO’s final guidance on section 100A was released on 8 December 2022 and includes changes that incorporated feedback received during public consultation.

Using case studies, this practical session will cover:

  • Where we’ve landed on section 100A, more than two year-ends on from the release of the ATO’s initial draft guidance in early 2022
  • Falling between the zones — when your clients’ arrangements differ from the ATO examples
  • Loans, gifts and undrawn amounts by family members — what is needed to demonstrate the beneficiary’s entitlement has been extinguished for their own benefit?
  • What supporting documentation is required to explain the transactions that have happened and what is the risk of trustees recording too much?
  Tax disputes
Session 4.2: Unique aspects of Default Assessments raised using Asset Betterment Methodology

Speaker: Prudence Barker, ATI, Victorian Bar


This session will explore: 

  • The nuances in the asset betterment methodology; 
  • Information the Commissioner of Taxation (Commissioner) may draw on to arrive at default assessment using the asset betterment methodology;
  • Understanding the burden of proof in default assessments; and
  • Assisting clients through the process.
  Emerging leaders
Session 4.3: Leadership in the new world

Speakers: Andy Hung, Wolters Kluwer, Victoria Lanyon, King & Wood Mallesons, Rachael McLean, Wolters Kluwer

With rapid development in technology, advisers of tomorrow (and today) need to develop a new, vastly different skill set. How practitioners adopt and use new technology,  stay on top of "the next big thing" and encourage those they are managing, may well be the key to a successful, long and rewarding career. 

This session will consider:

  • The interaction between technology and traditional business skills (eg using technology in meetings without creating a barrier between adviser and client)
  • Assessing the potential for integrating new technologies into practice (addressing concerns on confidentiality, accuracy and relevance); and
  • How to lead in this space, by encouraging colleagues to be agile as new technologies present themselves, and by ensuring continued professional development as technology replaces some of the “building block” tasks.
Session 4.4: Changes to the Thin Capitalisation Rules – Practical Insights

Speakers: Richard Goodwin, CTA, EY, Edward Ng, EY

The recently introduced changes to Australia’s thin capitalisation regime represent the biggest reform to the rules since their introduction. With a movement towards an earnings-based approach and changes to the alternative tests, organisations need to understand these important changes and their impact.

This session will explore the proposed changes to the rules and provide practical insights using examples and case studies.

  Lunch   |   12:30pm - 1:30pm
Breakout sessions   |   1:30pm - 2:30pm
Session 5.1: Small business CGT concessions – Accessing the proceeds from a company

Speakers: Karen Goodfellow, CTA, Practising Tax, Frederick Mahar, CTA,
F M Mahar & Associates

The small business CGT concessions are generous and can result in no tax being payable on company disposals of active assets, but how can shareholders access the proceeds?

This session will consider the issues that can arise when shareholders access the proceeds of non-taxable CGT events, either at the time of the event or on liquidation, such as:

  • The requirement that the company make a payment to a CGT concession stakeholder
  • How that payment is accounted for; and
  • What happens on liquidation.
Session 5.2: Is your PDA fit for purpose?

Speaker: Scott McGill, CTA, Pitcher Partners

Developers often want to acquire land comprised of several parcels (where parcels may be held by different owners or have different tax provenances) while maintaining a desire to pay by instalments and keep maximum flexibility.

This session will consider important aspects of Property Development Applications (PDAs) such as:

  • Inclusion of provisions for instalments
  • Dealing with parcels having different tax provenance (eg margin scheme, MRE or active asset)
  • Whether it matters if a parcel is on the vendor’s revenue account or capital account; and
  • Other important issues.
  Emerging leaders
Session 5.3: Foreign hybrid mismatch rules 101

Speaker: Robert James, FTI, Mazars


The foreign hybrid mismatch rules and the compliance burdens associated with them continue to provide organisations with practical challenges. 

While the rules are now five years old, this session is a back to basics, providing an overview on these complex rules through easy-to-follow examples and case studies.

Session 5.4: What is a reasonably arguable position and how to arrive at one

Speaker: Sue Williamson, CTA (Life), Holding Redlich

The consequences for making statements and taking positions to the ATO which are not reasonably arguable can be severe in terms of both  understanding the strength of your position and penalty exposures. This session will explore:

  • Whatis a reasonably arguable position
  • Objective assessment of facts
  • Reasonably arguable position versus private binding ruling
  • How to evidence your reasonably arguable position
  • Strategic advantages of having a reasonably arguable position
  • When and how to use a reasonably arguable position to best effect; and
  • The role of advisers and corporate governance in ensuring a reasonably arguable position exists.
  Afternoon tea   |   2:30pm - 3:00pm
  Breakout sessions   |   3:00pm - 4:00pm
Session 6.1: What’s on our radar?

Speakers: Denise Honey, CTA, Pitcher Partners, John Ioannou, CTA, Macpherson Kelley, Dr Mark Pizzacalla, CTA, BDO

Facilitator: Loreena Gillon, CTA, Arithmos Chartered Accountants

SME practitioners are often so busy addressing the latest issues, they have little time to contemplate whatmay be coming down the track.

In this session, you will hear from three senior practitioners around some of the issues starting to surface in the SME market. The panel will discuss:

  • How to identify the problem
  • Where is the mischief; and
  • Mitigation strategies.
Session 6.2: The main residence exemption - tips, traps, trips and tricks

Speaker: Neil Brydges, CTA, Sladen Legal


The CGT main residence exemption is a significant but deceptively complex concession, with many ways it can be gained, or inadvertently lost due to demolition, death, or absence.

This session will consider:

  • The significance of “adjacent land” for primary producers
  • Keeping the exemption when demolishing or subdividing the family home
  • When one dwelling can be two CGT assets
  • Planning for sea and tree changers with 2 dwellings
  • Impacts of death and inheritance
  • Absences, especially for foreign residents; and
  • Implications of the increasing use of main residences to derive income through modern work practices and “side hustles”.
  Emerging leaders
Session 6.3: Rollover Relief Roadmap: Merger Gains, Acquiring Tax Benefits!

Speaker: Ned Galloway, SW Accountants & Advisors

The session will provide an overview of CGT rollovers and the practical application to M&A transactions. The discussion will address technical challenges of accessing CGT rollovers for transactions based on a number of recent M&A transactions in practice.

The session will also examine the use of sequential rollovers for pre-acquisition restructuring.

Session 6.4: Tangling with transfer pricing – practicality of TP disputes

Speakers: Jerome Tse, CTA, King & Wood Mallesons, Calum Sargeant, King & Wood Mallesons


The session will focus on resolving transfer pricing disputes including:

  • Areas of technical focus
  • Practical management of the issues; and
  • Procedural practice and transition from Part IVC proceedings to MAP to arbitration.
 Session 7: Q&A Panel - Tax, climate and the economy - what does the future hold?   |   4:000pm - 5:30pm

   Panel: Bruce Billson, Australian Small Business and Family Enterprise Ombudsman, Scott Treatt, CTA, The Tax Institute,
   Cristina Wolters, CTA, Transurban, Danielle Wood, Grattan Institute 
   Facilitator: Ellen Fanning, Award winning current affairs journalist

The changes and challenges over the past few years have tested individuals, families, businesses, organisations and governments like never before. 

As we turn our focus to the future, what known and unknown challenges will we, our clients and our communities face?

How can we remain agile and continue to pivot, adjust and respond so we can manage whatever lays ahead and we and our clients are set up for every success?

This interactive Q&A session will:

  • Discuss the economic and political environment
  • Reflect on how the past few years will shape and impact policy development for years to come
  • Consider the role of tax in addressing policy design challenges as well as those associated with climate, innovation and technology
  • Look to the next 12 months and explore those issues you would be well advised to keep in your sights.
  Welcome reception   |   Cargo Hall   |   5:30pm - 7:30pm
  Session 8: Tax Policy and Advocacy panel session   |   8:30am - 9:15am

Panel: Scott Treatt, CTA, The Tax Institute, Julie Abdalla, FTI, The Tax Institute, Robyn Jacobson, CTA, The Tax Institute

Join The Tax Institute’s Tax Policy and Advocacy team as they discuss and address the latest key issues facing the tax and superannuation systems and the tax community.

Increased focus on the activities of the Tax Practitioners Board corresponds with its investigations and compliance programs that target the highest risk tax practitioners and the legislative changes following the Government’s response to the review of the TPB.

More than ever, tax practitioners need to keep pace with developments in the tax ecosystem so they can minimise risks to their own practices and their clients’ tax affairs.

  Session 9: Commissioner’s Address   |   9:15am - 10:00am

   Speaker: Chris Jordan AO, CTA, Commissioner of Taxation, Australian Taxation Office

In his final speech to the tax profession as Commissioner of Taxation, Chris Jordan will reflect on more than a decade of change and innovation, and challenge the tax profession in Australia to be ‘future fit’.

  Morning tea   |   10:00am - 10:30am
Breakout sessions   |   10:30am - 11:30am
Session 10.1: Common payroll tax mistakes 

Speaker: Matthew McKee, FTI, Brown Wright Stein Lawyers

Although state taxes don’t receive their fair share of attention, payroll tax is beginning to stand on its own. While it has been seen as a costly and annoying administrative burden, grudgingly accepted, recent cases have thrust it into the limelight.

This session will explore:

  • The myth of contractors (distinguishing between true contractors and contractors who are employees at common law)
  • Contractor exemptions – when they apply and when they don’t
  • The ongoing use of service entities, and their limitations; and
  • Grouping risks.
Session 10.2: Avoiding expensive mistakes– making a beneficiary entitled to real property

Speaker: Linda Tapiolas, CTA, Cooper Grace Ward

Practitioners quite regularly encounter a client who wants to take ownership of property held in a discretionary trust. This occurs most commonly in succession planning exercises, land tax minimisation planning or beneficiaries wanting to go their own way following relationship breakdowns.

This session considers:

  • What is required to transfer property to a beneficiary
  • The need to address the relevant trust law and tax law
  • How accounts can support what is to be attempted
  • Whether section 99B must be considered; and
  • Other traps to be avoided.
  Hot topics
Session 10.3 Case update 

Speaker: Mark Gioskos, FTI, Victorian Bar

This session will discuss a selection of the key tax cases from the last 12 months relevant to corporate taxpayers. It will consider the reasons for the decisions and the key implications for taxpayers.

Session 10.4: Pillar 2 – Where are we at?

Speakers: Sam Humphris, EY, Hector Thompson, Australian Taxation Office

The OECD’s Pillar 2 journey continues, and Australia’s approach is in full swing. In this session we will explore the current status of Pillar 2 and provide details of the recent guidance. We will also hear about Australia’s journey towards Pillar 2 implementation and insights from the ATO.

Breakout sessions   |   11:30am - 12:30pm
Session 11.1: Division 7A  

Speaker: Todd Want, CTA, William Buck

Despite Division 7A having been with us for more than a quarter of a century, it has continued to wreak havoc for practitioners and their clients. This session will explore some of the more common nuances when handling old Division 7A problems for new clients including:

  • Whether doing nothing is an option
  • What constitutes an honest and inadvertent mistake
  • A re-enlivening of section 109R; and
  • A reminder on interposed entities.
Session 11.2: Do you have a choice about whether the property transaction is on revenue account or capital account?

Speaker: Thomas Aitkenhead, CTA, Hoffman Kelly

The ATO’s exercise to source and match data about 1.7 million investment property loans annually will provide the ATO with a gateway to a matrix of data to identify and construe intention. Examples will be used to identify the rough times ahead for property flippers and others returning construction activity on capital account including:

  • A brief recap of revenue or capital principles and the key element of intention
  • What information is being data matched and what will that matching reveal
  • How is the intention of a ‘virgin’ entity ascertained
  • Can the holder of a minority interest control an entity; and
  • Does cash activity remain beyond data matching?
  Hot topics
Session 11.3: Employee v contractor 

Speaker: Greg Protektor, King & Wood Mallesons

The employee/contractor distinction is important in a number of areas of taxation, including PAYG, fringe benefits tax, superannuation and payroll tax.

With recent High Court decisions, and with the Commissioner issuing a new draft ruling, it is back in the spotlight, with greater uncertainty for practitioners and clients alike, only compounded by changes in the workplace model. This session will explore:

  • The rules and how they are developing, both legally practically
  • The impact of the Commissioner’s guidelines; and
  • The flow-on effect for superannuation and fringe benefits tax.
Session 11.4: Have you seen my intangible? The many touchpoints in the law for intangibles issues

Speakers: Jeremy Geale, CTA, MinterEllison, Amelia Teng, Deloitte

This session will explore the range of interconnected issues relating to intangibles including the technical rules that impact intangibles and the array of measures that multinationals need to consider.

Lunch and Session 12: Inspector-General of Taxation and Taxation Ombudsman Address   |   12:30pm - 2:00pm (session will commence at 1:15 pm) 

   Speaker: Karen Payne, CTA, Inspector-General of Taxation and Taxation Ombudsman

The Inspector-General and Taxation Ombudsman (IGTO) performs an important role in maintaining the integrity of the taxation administration system. The Budget Outcome Statement for the IGTO is as follows:

Fair, accountable and improved administration and integrity of the taxation and superannuation systems for the benefit of the Australian community, through independent investigation and reporting

The IGTO improves transparency, integrity and fairness of the tax system, by independently investigating taxation decisions, actions, systems and laws of the Australian Taxation Office or the Tax Practitioners Board and publicly reporting where this is in the public interest.

Independent investigation advances community trust and provides assurance that there is fair and effective public administration of the tax system. In doing so, the IGTO improves taxation administration and voluntary compliance with taxation systems and laws. In an age where the ATO and TPB have wide reaching statutory powers, the function performed by the IGTO’s office provides a critical means of ensuring that taxation laws are applied in a way that is consistent with community expectations and fairness.

Breakout sessions   |   2:00pm - 3:00pm
Session 13.1: Structuring family offices: commercial and tax considerations 

Speakers: Shaun Cartoon, FTI, Arnold Bloch Leibler, Christine Fleer, Arnold Bloch Leibler

High wealth family groups are increasingly looking to establish family offices to unite generations and preserve wealth. With no set playbook, the range of family offices is as diverse as the family groups that establish them. This session will cover:

  • Key commercial and tax considerations for the decision to establish a family office
  • Trends in structuring
  • Incentive arrangements for employees
  • Family governance and succession planning issues
  • Multi-jurisdictional commercial and tax issues; and
  • Intergenerational change – how to unwind a family office if the next generation doesn’t want to be involved.
Session 13.2: The challenges raised by live data feeds including Single Touch Payroll

Speaker: Andrew Sommer, CTA, Clayton Utz

Live data feeds to the ATO are a fact of life. STP is an intermittently live data feed. The expectation is that more and more information will be provided to the Commissioner in “real time”.

This session will consider:

  • Is the provision of a “live stream” of raw data the making of a “statement” to the Commissioner?
  • How do taxpayers and the Commissioner handle the inevitable errors in the live data feed?
  • What further issues arise when reporting, assessment and payment are all conducted in real time?
  • Is it time for a wholesale review of the law in this area?
  Hot topics
Session 13.3: Context in which the “new” Part IVA has been applied and resulting evidentiary issues for taxpayers

Speakers: Claire Horan, Victorian Bar, Luke Imbriano, FTI, KPMG Law

The ‘new’ Part IVA is no longer so new, but following some recent guidance on its application, it needs revisiting. This session will look at the recent cases which have considered the operation of Part IVA including Guardian and Minerva, and consider how to manage some of the evidentiary issues which arise in Part IVA cases.

Session 13.4: Tapped out on Treaties & TARP

Speaker: Andrew de Wijn, Victorian Bar

Foreign Investors with capital gains on significant investments in Australia should be aware of the current landscape in relation to Taxable Australian Real Property (TARP). This session will explore:

  • The key decisions in this area, including RCF
  • The interaction between Division 855 and Australia’s Double Tax Agreements. 
  • The ATO’s perspectiveon these issues
  • The steps the ATO is likely to manage any “risk to the revenue”; and 
  • What taxpayer’s faced with an assertion that tax ought to be paid upfront can do to manage their risk.
  Afternoon tea   |   3:00pm - 3:30pm
  Breakout sessions   |   3:30pm - 4:30pm
Session 14.1: Before you start my tax, me and Finley are splitting

Speaker: Chris Wallis, CTA, Victorian Bar

When faced with potential marital/relationship breakdown, the taxation implications of the division of assets and entities is often the last thing on a client’s mind. Structures evolve over time, and are usually established with little or no consideration of the possibility of divorce.

This is a critical topic and impacts all SME practitioners at some point with considerations including:

  • Entity control and continuity of ownership issues
  • UPE’s, Div 7A and Family Trust Election implications
  • Revision of Trust Deeds, including Guardian or Appointor
  • Impact on Business Real Property
  • Superannuation and CGT Asset Rollovers available
  • Ethical issues; and
  • Recent case law.
Session 14.2: Hunted by hackers? Cyber risk and client/supplier created exposures

Speaker: Chris Watson, Grant Thornton

There is increasing media attention to the “big game” targets of cyber-crime, but is your practice next to be hunted?

This session will explore the current and emerging areas of cyber exposure and identify strategies recommended by the Australian Cyber Security Centre  to mitigate risk, including:

  • Cyber security for remote workers
  • Business email compromise 
  • Exposures through managed service providers
  • Implementation of the Essential Eight cyber security strategies
  • Emerging best practice strategies including Zero Trust; and
  • What to do if your practice is hacked.
  Hot topics
Session 14.3: Employment taxes, it's a personnel question: an overview of Employment taxes, inlcuidng updates on recent law changes and regulator activity

Speakers: Stephen Chen, CTA, Minter Ellison, Elissa Romanin, Minter Ellison

Employment taxes and getting it right is as relevant as ever. This session will cover the various employment tax obligations, essentially an employer’s comprehensive checklist, what the current state of play is, and how to avoid and/or deal with regulator scrutiny over these obligations.

This session will firstly provide a summary of the current state of play in employment tax issues, with specific focus on recent decisions relating to the employee/contractor distinction; issues concerning the superannuation guarantee charge and payroll tax measures.

Secondly, the session will examine recent regulator action in respect of employment tax issues, which specific employment tax issues and industries are attracting attention from Federal and State revenue authorities, and how to avoid and resolve employment tax disputes.

Session 14.4: Anti-Avoidance Rules – Where are we at?

Speaker: Fiona Knight, CTA, Australian Taxation Office

Australia’s tax law has several anti-avoidance provisions and we have seen some significant developments in the past 12 months, in terms of recent cases, ATO practices and proposed new anti-avoidance rules. In this session we will provide an overview of the anti-avoidance landscape and provide practical insights and perspectives from both advisers and the ATO.

  Breakout sessions   |   4:30pm - 5:30pm
Session 15.1: Deceased estates - Taxation nirvana or Frankenstein’s monster

Speaker: Ian Raspin, CTA, BNR Partners

It has famously been said that nothing is certain except death and taxes. Death opens the door to many tax concessions. However, the interaction between taxation law (and lore) and deceased estates is complex and often poorly understood. Getting it wrong can turn what could have been taxation nirvana into some kind of monster – all while dealing with grieving families.

This session will cover taxation issues around:

  • Present entitlement and who pays the tax
  • Residency of the estate and foreign resident beneficiaries
  • The main residence exemption; and
  • Specific legacies and life and remainder interests.
Session 15.2: Is there Panadol for crypto and NFT headaches? 

Speaker: Joni Pirovich, Block Chain + Digital Assets

Blockchain technologies that support crypto-token activities including NFTs carry significant record keeping burdens. Various software products have been developed to assist taxpayers and practitioners in meeting the record-keeping and rorting obligations.

This session will explore:

  • How blockchain works
  • How much faith you can have in software packages designed for crypto-token activities including NFT transactions; and
  • Key risks for tax agents and tax practitioners relying on software packages, and mitigation measures.
  Hot topics
Session 15.3: Why salads are now being taxed and Teslas are not - an update on recent developments on GST and FBT

Speaker: Rachel O'Donnell, CTA, O’Donnell Tax Law

GST impacts almost all transactions that businesses are involved in and getting it wrong can have catastrophic consequences.  Together with an update on FBT, this session looks at the developments in GST you need to be aware of, including:

  • GST in property contracts and sub-divisions
  • GST and globalisations; and
  • The ATO's attention to the GST treatment of food classification; and 
  • How FBT applies to electric vehicles.
Session 15.4: Heads of Tax panel

Panel: Clint Collins, REA GroupJanelle O'Hare, Santos, Stephen Southon, ATI, National Australia Bank
Facilitator: Amelia Teng, Deloitte

Hear the latest insights from leading Heads of Tax on relevant tax matters over the last 12 months, including:

  • ATO engagement
  • Tax technology
  • Workforce constraints
  • Development of tax technical matters and impacts on the tax function
  • Tax governance; and
  • Board reporting.
  Delegate free time   |   5:30pm
  Gala Dinner   |   7:00pm
  Session 16: VIP Presentation |   8:30am - 9:30am

  Speaker: David Thodey AO, Chair of Xero, Director and Chair in waiting at Ramsay

Hear first-hand from a key and influential decision maker. A session not to be missed!

  Breakout sessions   |   9:30am - 10:30am
Session 17.1: ATO nudge theory in action - Allocation of professional firm profits

Speaker: Alan Krawitz, CTA, Smailes

This session will detail the ATO’s compliance approach to the allocation of professional firm profits, and what you should consider, including:

  • Understanding the ‘Gateways’ and calculating your score
  • ATO engagement and your risk assessment;
  • Documenting your arrangements
  • Everett and Galland assignments; and
  • Restructuring to comply with the PCG.
Session 17.2: The nasty implications of ‘off the cuff advice’

Speaker: Michael Bearman, CTA, Victorian Bar

There are many reasons for advice, usually free, being given "off the cuff". This session will explore the implications and will consider: 

  • The scope of "off the cuff advice"
  • How, when and why "off the cuff advice" is given
  • "Off the cuff advice" by phone or email
  • The importance of the client receiving the advice
  • Does your PI policy cover "off the cuff advice"?
  • Might the "off the cuff advice" be legal advice; and
  • What will the Statement of Claim look like?
  Hot topics
Session 17.3 Debt recovery and restructuring

Speaker: Tianne Nagy-Jones, Grant Thornton

One of the long-term impacts from COVID is $45 billion in collectible tax debt. As the ATO re-focus on this problem, and businesses are also dealing with a number of headwinds, tax debt, insolvency and restructuring are going to be some of the hot topics for the year ahead.

This session will discuss what this means for businesses impacted, including:

  • What options are available for business and how can they restructure or trade-out of a tax debt
  • The personal liabilities for tax debts that directors need to be aware of
  • What to do if you or your client can’t pay their tax debt; and
  • What are some of the early warning signs of distress to look out for and when to take action.
Session 17.4: Capital (+) or Deductible (-) employee expenses: Clough Engineering’s enduring last gasp

Speakers: Denise Brotherton, BDO, Catherine Dean, CTA, BDO

The question of whether an employee expense is capital in nature or on revenue account is not always clear. This is a topic that is increasingly coming under spotlight before the Courts. In the Clough Limited decision, the Full Federal Court added to the long-running history of revenue versus capital cases, and considered the deductibility of employee entitlements under sections 8-1 and 40-880.

This session will explore the key principles emerging from Clough and considerations for taxpayers looking to make and support a deduction both generally, and particularly relating to employee entitlements.

  Morning tea |   10:30am - 11:00am
Breakout sessions   |   11:00am - 12:00pm
Session 18.1: SMSF update – a snapshot of industry activity

Speaker: Liz Westover, FTI, Deloitte

Within an ever changing and evolving SMSF industry, Liz will ensure that delegates walk away with a clear understanding of recent changes and contentious issues affecting them and their clients.  

She will discuss what’s new from the legislators and key focus areas of the regulators. With a practical approach, Liz will provide insights into adapting to changes as well as identify some of the more challenging and problematic areas for practitioners and how best to navigate them.

Session 18.2: Are you being dragged unwittingly onto a slippery slope?

Speakers: Craig Jackson, CTA, EY, Hoa Wood, Australian Taxation Office

Various authorities are increasing their scrutiny of the assistance provided by practitioners in relation to client activities. No matter your professional background we all have ethical obligations. We need to make sure that we do not step over those lines which sometimes may be hard to see.

We need to consider what we are doing and ask if we are:

  • assisting in something that could be in relation to suspected illegal activities
  • bending the truth through, say, providing favourable valuations, possibly in relation to a Family Law Conflict.

This session will help you to:

  • recognise the warning signs; and
  • develop appropriate preventative strategies

This session will be conducted by way case studies, each focusing on ethical issues.

  Hot topics
Session 18.3: Addressing
collectable tax debt - ATO perspective and what to expect

Speaker: Vivek Chaudhary, Australian Taxation Office

At the end of 2022, collectible tax debt was $45 billion and growing.  The ATO have foreshadowed a re-focusing on debt and in this session, we will hear from the ATO and what that means, including:

  • What are the targeted strategies the ATO will be deploying to stop the growth in tax debt; and
  • How will they be engaging with tax professionals and taxpayers.
Session 18.4: Practical issues in responding to RFIs and notices

Speakers: Stan Spasojevic, Australian Taxation Office, Annemarie Wilmore, Johnson Winter Slattery

The Commissioner has a broad range of powers under domestic legislation, and through exchange of information protocols, to access information about taxpayers. This includes informal requests for information and more formally through issuing statutory notices.

This practical session will focus on:

  • The extent of the Commissioner’s powers, both within Australia and overseas
  • How to respond to requests in a way that provides the Commissioner with assurance?
  • The trips and traps
  • How to manage and respond to requests to third parties or offshore related parties; and
  • The important considerations when determining how to respond to a request.
  Breakout sessions   |   12:00pm - 1:00pm
Session 19.1: Dystopian discretionary distribution resolutions

Speaker: Ron Jorgensen, CTA, Thomson Geer

Since the ATO Ruling, TR 2012/D1, we have lived in the Dystopian world of Area 56 – Income of the Trust Estate and Area 57 – Statement of Distribution. Income is notional, deductions quarantined, tax attributes disembodied and trustees re-educated by Practical Compliance Guidelines and Alerts.

This session discusses the distribution dystopia and compliant and rebellious procedures and distribution resolutions including:

  • Complex, Boolean and tax adjusted resolutions for notional income, corpus and tax benefits streaming
  • Distributions of assets made in specie; and 
  • Distributions attributable to asset revaluation reserves.
Session 19.2: Traumatised by a client’s audit? Asking for a friend!

Speaker: Andrew O’Bryan, CTA, Hall & Wilcox

Being notified of a review or an audit is a stressful event in a person’s life. Many organisations and institutions have recognised the risk of vicarious trauma for those dealing with the subject person and this session will consider:

  • How to recognise a traumatised client
  • Handling the traumatised client
  • How the client’s trauma can be transferred to a practitioner; and
  • Protecting yourself or an employee from vicarious trauma.
  Hot topics
Session 19.3: 99B and the Temple of Doom

Speakers: Kaitilin Lowdon, ATI, Arnold Bloch Leibler, Jonathan Ortner, FTI, Arnold Bloch Leibler

Deep in the mountainous abyss of the taxation of trusts lives an anti-avoidance provision, which until recently, was rarely disturbed. The ATO have resurrected Section 99B from its slumber. It is ugly and mean-spirited, frightening even to the most seasoned advisor in its potential breadth. This session will:

  • Provide an overview of the history and purpose of Section 99B
  • Provide practical examples of when Section 99B can apply, including the application of Section 99C
  • Explain why proving the corpus exception is like finding the mystical stone; and
  • Explain how managing a Section 99B audit can feel like being ambushed while crossing a rope bridge.
Session 19.4: Economic update

Speaker: Cherelle Murphy, EY

As higher interest rates slow growth, but inflation remains problematic, policy makers are grappling with difficult macroeconomic conditions around the world.

This session will explore the global economic backdrop, banking volatility in US and Europe and what it all means for Australia.

  Session 20: Closing keynote - Seated lunch  |    1:00pm - 2:30pm

   Speaker: Kevin Sheedy AO, Australian Sporting Legend

Find your inner champion. Learn what it takes to build a winning team, create a future focussed game plan and unleash your inner champion with AFL legend Kevin Sheedy.

A great opportunity to reward yourself and your team at our closing lunch keynote, Kevin will share his unique perspective on how self-development, much like training for a championship, is the ultimate game of honing your skills and unlocking your own, and team’s, full potential.


Technical Streams