This paper discusses unsettled audits, in particular:
- What to expect
- setting the boundaries: the years, issues and length of time
- answering information requests and section 263
- Section 264 interviews
- negotiating and communicating with the ATO
- settling an audit.
- What to do about assessment issues
- the assessment procedure
- objecting to an assessment - some drafting tips
- what if an objection is disallowed?
- gathering evidence.
- Challenging an assessment
- Part IVC proceedings - what you need to know
- where to go - AAT or Federal Court?
- proceedings in the Federal Court; the new "Fast Track List" and Tax List Directions
- expert evidence - some practical advice
- test case funding
- the role of a barrister.