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An update on tax audits and disputes presentation
Published on 18 Mar 15 by NATIONAL DIVISION, THE TAX INSTITUTE
This presentation covers:
- introduction, context and recent history
- drivers for change
- some recent changes
- the view from the profession
- what to expect in 2015.
Author profiles:
Ashley King CTA
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
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Damien Browne
Damien is an Assistant Commissioner in ATO Review and Dispute Resolution, which is responsible for ATO dispute resolution policy and practices, including running the Independent Review service and managing ATO litigation. Increasingly, the ATO is using alternative dispute resolution to better resolve and manage disputes. Damien joined the ATO in 2007 from the Commonwealth Ombudsman’s office, where he was variously responsible for information technology, public and international affairs, public contact, and the taxation and Defence Force Ombudsman roles. He was responsible for the ATO’s public advice policy, and National Practice Manager for legal services, prior to taking on his current role. Current at 01 October 2014This was presented at 30th National Convention.
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Individual sessions
Are tax havens dead?
Author(s): David RUSSELLMaterials from this session:
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DisclaimerThese materials are copyright. Apart from any fair dealing for the purposes of private study, research, criticism or review, as permitted under the Copyright Act, no part may be reproduced by any process without written permission from The Tax Institute.
Unless expressly stated, opinions are not that of The Tax Institute, which accepts no responsibility for the accuracy of any of the information contained within it.
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Unless expressly stated, opinions are not that of The Tax Institute, which accepts no responsibility for the accuracy of any of the information contained within it.
The Board of Tax Review of the debt/equity rules
Author(s): Teresa DYSONMaterials from this session:
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DisclaimerThese materials are copyright. Apart from any fair dealing for the purposes of private study, research, criticism or review, as permitted under the Copyright Act, no part may be reproduced by any process without written permission from The Tax Institute.
Unless expressly stated, opinions are not that of The Tax Institute, which accepts no responsibility for the accuracy of any of the information contained within it.
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Unless expressly stated, opinions are not that of The Tax Institute, which accepts no responsibility for the accuracy of any of the information contained within it.
Tax issues in structuring an effective executive package
Author(s): Andy HuttMaterials from this session:
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DisclaimerThese materials are copyright. Apart from any fair dealing for the purposes of private study, research, criticism or review, as permitted under the Copyright Act, no part may be reproduced by any process without written permission from The Tax Institute.
Unless expressly stated, opinions are not that of The Tax Institute, which accepts no responsibility for the accuracy of any of the information contained within it.
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Unless expressly stated, opinions are not that of The Tax Institute, which accepts no responsibility for the accuracy of any of the information contained within it.
Tax risk management
Author(s): Alison Feather, Peter NearhosMaterials from this session:
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DisclaimerThese materials are copyright. Apart from any fair dealing for the purposes of private study, research, criticism or review, as permitted under the Copyright Act, no part may be reproduced by any process without written permission from The Tax Institute.
Unless expressly stated, opinions are not that of The Tax Institute, which accepts no responsibility for the accuracy of any of the information contained within it.
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Unless expressly stated, opinions are not that of The Tax Institute, which accepts no responsibility for the accuracy of any of the information contained within it.
Recent cases
Author(s): Philip BENDERMaterials from this session:
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DisclaimerThese materials are copyright. Apart from any fair dealing for the purposes of private study, research, criticism or review, as permitted under the Copyright Act, no part may be reproduced by any process without written permission from The Tax Institute.
Unless expressly stated, opinions are not that of The Tax Institute, which accepts no responsibility for the accuracy of any of the information contained within it.
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Unless expressly stated, opinions are not that of The Tax Institute, which accepts no responsibility for the accuracy of any of the information contained within it.
Issues facing parents and subsidiaries in the current international tax climate
Author(s): Peter MCCULLOUGHMaterials from this session:
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DisclaimerThese materials are copyright. Apart from any fair dealing for the purposes of private study, research, criticism or review, as permitted under the Copyright Act, no part may be reproduced by any process without written permission from The Tax Institute.
Unless expressly stated, opinions are not that of The Tax Institute, which accepts no responsibility for the accuracy of any of the information contained within it.
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Unless expressly stated, opinions are not that of The Tax Institute, which accepts no responsibility for the accuracy of any of the information contained within it.
Tax effective extraction of retained earnings from “dormant” private companies: Case studies
Author(s): Paul HOCKRIDGEMaterials from this session:
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DisclaimerThese materials are copyright. Apart from any fair dealing for the purposes of private study, research, criticism or review, as permitted under the Copyright Act, no part may be reproduced by any process without written permission from The Tax Institute.
Unless expressly stated, opinions are not that of The Tax Institute, which accepts no responsibility for the accuracy of any of the information contained within it.
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Unless expressly stated, opinions are not that of The Tax Institute, which accepts no responsibility for the accuracy of any of the information contained within it.
Small business CGT case study
Author(s): Brian J RICHARDSMaterials from this session:
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DisclaimerThese materials are copyright. Apart from any fair dealing for the purposes of private study, research, criticism or review, as permitted under the Copyright Act, no part may be reproduced by any process without written permission from The Tax Institute.
Unless expressly stated, opinions are not that of The Tax Institute, which accepts no responsibility for the accuracy of any of the information contained within it.
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Unless expressly stated, opinions are not that of The Tax Institute, which accepts no responsibility for the accuracy of any of the information contained within it.
Deceased estates: A practical perspective
Author(s): Loreena GillonMaterials from this session:
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DisclaimerThese materials are copyright. Apart from any fair dealing for the purposes of private study, research, criticism or review, as permitted under the Copyright Act, no part may be reproduced by any process without written permission from The Tax Institute.
Unless expressly stated, opinions are not that of The Tax Institute, which accepts no responsibility for the accuracy of any of the information contained within it.
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The Income Tax Assessment Acts: Statutes in senescence
Author(s): AH (Tony) SLATERMaterials from this session:
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Practical management of Division 7A
Author(s): Adele TownsendMaterials from this session:
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DisclaimerThese materials are copyright. Apart from any fair dealing for the purposes of private study, research, criticism or review, as permitted under the Copyright Act, no part may be reproduced by any process without written permission from The Tax Institute.
Unless expressly stated, opinions are not that of The Tax Institute, which accepts no responsibility for the accuracy of any of the information contained within it.
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Unless expressly stated, opinions are not that of The Tax Institute, which accepts no responsibility for the accuracy of any of the information contained within it.
Win your privatisation bid for infrastructure assets by optimising capital allowances
Author(s): Chris McLean, Hayden SCOTTMaterials from this session:
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DisclaimerThese materials are copyright. Apart from any fair dealing for the purposes of private study, research, criticism or review, as permitted under the Copyright Act, no part may be reproduced by any process without written permission from The Tax Institute.
Unless expressly stated, opinions are not that of The Tax Institute, which accepts no responsibility for the accuracy of any of the information contained within it.
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Unless expressly stated, opinions are not that of The Tax Institute, which accepts no responsibility for the accuracy of any of the information contained within it.
Solving inherited problems
Author(s): Andrew NOOLANMaterials from this session:
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DisclaimerThese materials are copyright. Apart from any fair dealing for the purposes of private study, research, criticism or review, as permitted under the Copyright Act, no part may be reproduced by any process without written permission from The Tax Institute.
Unless expressly stated, opinions are not that of The Tax Institute, which accepts no responsibility for the accuracy of any of the information contained within it.
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Unless expressly stated, opinions are not that of The Tax Institute, which accepts no responsibility for the accuracy of any of the information contained within it.
The latest on the ATO’s management of tax audits and disputes
Author(s): Damien BROWNE, Ashley KINGMaterials from this session:
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Trusts - Current risk areas
Author(s): Renuka SOMERS, Daniel SMEDLEY, Patricia MartinsMaterials from this session:
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DisclaimerThese materials are copyright. Apart from any fair dealing for the purposes of private study, research, criticism or review, as permitted under the Copyright Act, no part may be reproduced by any process without written permission from The Tax Institute.
Unless expressly stated, opinions are not that of The Tax Institute, which accepts no responsibility for the accuracy of any of the information contained within it.
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Unless expressly stated, opinions are not that of The Tax Institute, which accepts no responsibility for the accuracy of any of the information contained within it.
Practical realities of being a tax advisor
Author(s): Scott TREATTMaterials from this session:
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DisclaimerThese materials are copyright. Apart from any fair dealing for the purposes of private study, research, criticism or review, as permitted under the Copyright Act, no part may be reproduced by any process without written permission from The Tax Institute.
Unless expressly stated, opinions are not that of The Tax Institute, which accepts no responsibility for the accuracy of any of the information contained within it.
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Grouping for payroll tax
Author(s): Philip MAGOFFINMaterials from this session:
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DisclaimerThese materials are copyright. Apart from any fair dealing for the purposes of private study, research, criticism or review, as permitted under the Copyright Act, no part may be reproduced by any process without written permission from The Tax Institute.
Unless expressly stated, opinions are not that of The Tax Institute, which accepts no responsibility for the accuracy of any of the information contained within it.
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Unless expressly stated, opinions are not that of The Tax Institute, which accepts no responsibility for the accuracy of any of the information contained within it.
The abandoned education cap policy: Public participation in tax reform consultation
Author(s): Peter BOBBINMaterials from this session:
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DisclaimerThese materials are copyright. Apart from any fair dealing for the purposes of private study, research, criticism or review, as permitted under the Copyright Act, no part may be reproduced by any process without written permission from The Tax Institute.
Unless expressly stated, opinions are not that of The Tax Institute, which accepts no responsibility for the accuracy of any of the information contained within it.
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Professional practice structures
Author(s): Ash CHOTAIMaterials from this session:
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DisclaimerThese materials are copyright. Apart from any fair dealing for the purposes of private study, research, criticism or review, as permitted under the Copyright Act, no part may be reproduced by any process without written permission from The Tax Institute.
Unless expressly stated, opinions are not that of The Tax Institute, which accepts no responsibility for the accuracy of any of the information contained within it.
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Unless expressly stated, opinions are not that of The Tax Institute, which accepts no responsibility for the accuracy of any of the information contained within it.
Vesting trust deeds
Author(s): Michael BUTLERMaterials from this session:
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DisclaimerThese materials are copyright. Apart from any fair dealing for the purposes of private study, research, criticism or review, as permitted under the Copyright Act, no part may be reproduced by any process without written permission from The Tax Institute.
Unless expressly stated, opinions are not that of The Tax Institute, which accepts no responsibility for the accuracy of any of the information contained within it.
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Tax mistakes - The tax practitioner obligation
Author(s): Mark BirdMaterials from this session:
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DisclaimerThese materials are copyright. Apart from any fair dealing for the purposes of private study, research, criticism or review, as permitted under the Copyright Act, no part may be reproduced by any process without written permission from The Tax Institute.
Unless expressly stated, opinions are not that of The Tax Institute, which accepts no responsibility for the accuracy of any of the information contained within it.
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Unless expressly stated, opinions are not that of The Tax Institute, which accepts no responsibility for the accuracy of any of the information contained within it.
When is a company incorporated outside Australia a resident of Australia?
Author(s): Chloe BURNETTMaterials from this session:
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DisclaimerThese materials are copyright. Apart from any fair dealing for the purposes of private study, research, criticism or review, as permitted under the Copyright Act, no part may be reproduced by any process without written permission from The Tax Institute.
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Unless expressly stated, opinions are not that of The Tax Institute, which accepts no responsibility for the accuracy of any of the information contained within it.
Revenue versus capital: That old chestnut
Author(s): Katrina PARKYN, Jay PrasadMaterials from this session:
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DisclaimerThese materials are copyright. Apart from any fair dealing for the purposes of private study, research, criticism or review, as permitted under the Copyright Act, no part may be reproduced by any process without written permission from The Tax Institute.
Unless expressly stated, opinions are not that of The Tax Institute, which accepts no responsibility for the accuracy of any of the information contained within it.
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Unless expressly stated, opinions are not that of The Tax Institute, which accepts no responsibility for the accuracy of any of the information contained within it.
M&A taxation: Roasting old chestnuts
Author(s): Edward Consett, Ken SPENCEMaterials from this session:
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DisclaimerThese materials are copyright. Apart from any fair dealing for the purposes of private study, research, criticism or review, as permitted under the Copyright Act, no part may be reproduced by any process without written permission from The Tax Institute.
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Unless expressly stated, opinions are not that of The Tax Institute, which accepts no responsibility for the accuracy of any of the information contained within it.
Tax issues arising from maturing situations in the context of SMSFs
Author(s): Chris BALALOVSKIMaterials from this session:
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DisclaimerThese materials are copyright. Apart from any fair dealing for the purposes of private study, research, criticism or review, as permitted under the Copyright Act, no part may be reproduced by any process without written permission from The Tax Institute.
Unless expressly stated, opinions are not that of The Tax Institute, which accepts no responsibility for the accuracy of any of the information contained within it.
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