Kristie Schubert

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Kristie Schubert, CTA is a Partner in KPMG Law’s Tax Dispute Resolution & Controversy practice. In addition to many years working as an adviser to clients in Australia and the UK, Kristie has also previously worked for several years as a Senior Litigator at the ATO, as well as in the position of Tax Controversy Director for a large multi-national technology company, primarily focused on managing transfer pricing disputes. This experience is unique, giving Kristie the benefit of experience across the three lenses of a tax dispute (adviser, tax authority and client) and from a truly international platform.

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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.