I have been practising tax for over 24 years across in Auckland, Sydney, Perth and Brisbane (since 2011). My experience spans a wide spectrum of international and Australasian organisations, including within agriculture, financial services, retail, consumer markets, life sciences, technology, services, industrials, health, education, property, energy and natural resources industries. These range from major corporations, multinationals to small-medium family businesses.

My areas of expertise include helping clients address tax issues relating to the sale and purchase of businesses, tax structuring, capital management, ATO engagement, tax planning as well as identifying tax-efficient inbound and outbound investment structures and financing.

• Tax partner at a Big 4 accounting firm for 10 years providing advice to private, ASX listed and multinational organisations.
• Led the tax aspects of a foreign oil and gas (mid-stream and down-stream) operator setting up operations in Australia (tax consolidation, funding etc.) whilst undertaking several large acquisitions.
• Led significant M&A transactions include the acquisition of a lotteries business, the acquisition of a childcare group, the ASX listing of a property trust, to name just a few.
• Provided advice around the location of valuable intellectual property in a multinational group.
• Assisted clients in 'unwinding' cross-border structures, including redeemable preference shares, a US general partnership and a circular shareholding, including delivering ATO signoff.
• Successfully assisted numerous 'top 1,000' taxpayers through ATO reviews.
• Helped ASX listed companies migrate offshore.
• Assisted numerous Not-for-Profits such as Camp Quality, MS and OrangeSky.

*not an Australian legal practitioner

• Road user charging: post-Vanderstock, towards decarbonisation
  

  The High Court's decision that Victoria's distance-based EV charge is unconstitutional raises questions about how road infrastructure should be funded.

• Franked dividends – what a difference 3 years can make!
  

  Insights on the Government's proposed legislation which has retrospective impact on franked dividends and capital raisings.

• Federal Budget 2024/25 Highlights
  

  The Government's Budget forecasts a budget surplus in the 2023-2024 year, followed by larger deficits than expected across the next 4 years.

• Federal Budget 2023/24 Highlights
  

  MinterEllison explores the impact and implications across the key tax related focus areas raised in the 2023/24 Federal Budget announcement.

• Federal Budget 2022/23 Highlights
  

  The 2022/23 Budget primarily provides targeted cost-of-living relief and sets out how the Government intends to invest in Australia's future in times of economic and inflationary pressures as well as continuing global uncertainty. MinterEllison explores the impact and implications across the key commercial focus areas raised in the Government's Budget announcement.

• The road ahead: Funding road infrastructure post Vanderstock
  

  With the future of road infrastructure funding in limbo, new approaches warrant consideration.

• March Federal Budget 2022/23 Highlights
  

  An election year Federal Budget has announced significant personal tax measures as expected, with a focus on addressing cost of living pressures in a time of rising inflation.

• ATO Tax Collection: Public Beneficial Ownership Register Treasury paper released
  

  With 3 million unlisted entities impacted in phase 1, the proposed beneficial ownership disclosure requirements will require close stakeholder engagement, strict ongoing compliance and reporting obligations under high public scrutiny.

• ATO's draft guidance on the application of section 99B: On the right track, but far from the finish line
  

  The ATO provides guidance on its approach to the application of section 99B, giving taxpayers valuable clarity on common scenarios and in relation to the evidentiary aspects to support the availability of an exemption.

   

• Medical practices and payroll tax: the current state of play
  

  Medical practices that engage practitioners as contractors need to urgently review their payroll tax position due to recent revenue office rulings.

   

• Off Market Share Buy-Back Exposure Draft Legislation released
  

  On 17 November 2022, the Government announced exposure draft legislation to enact measures announced in the October Budget to align the tax treatment of on-market and off-market share buy-backs.

• Tax updates to proposed intangibles integrity measure
  

  Updates to the proposed tax reform measures preventing multinationals from claiming Australian tax deductions for certain payments made for the use of intangible assets to foreign associates in low-tax jurisdictions.

• Australian Government's Critical Minerals Development Program: applications close 20 February 2023
  

  Grant money can be spent on project activities that are undertaken post-exploration and before final investment decision; have at least $2 million in eligible expenditure; and are substantially undertaken in Australia.

• Is an unpaid present entitlement a 'loan'?
  

  The Commissioner has appealed the AAT's ruling that an unpaid present entitlement does not constitute a loan under Division 7A of the ITAA36.

   

• A 'thin new world' part 2 – proposed changes to Australia's thin capitalisation provisions
  

  Under proposed new law, organisations may be limited in their ability to claim debt deductions from 1 July 2023.

• Tangible consequences for SGEs: Proposed changes to intangible asset exploitation in low-corporate tax jurisdictions
  

  Australian Treasury proposes new rules to limit significant global entities from claiming deductions for payments made to associates in low corporate tax jurisdictions related to intangibles from 1 July 2023.

   

• Electric car FBT exemption
  

  The Government has introduced a new Bill to exempt from fringe benefits tax (FBT) electric cars provided to employees for their private use.

• A 'thin' new world - Proposed changes to Australia's thin capitalisation rules
  

  Under proposed new law, organisations may be limited in their ability to claim debt deductions from 1 July 2023.

• Federal Government introduces legislation for Patent Box tax scheme
  

  The much anticipated 'patent box' tax scheme, first proposed in last year's Federal Budget, has taken a further step towards implementation, with the Government introducing draft legislation into Parliament on 10 February 2022.

   

• Australia's thin capitalisation rules – finally, the amending Bill to a Bill to amend
  

  We explore the new exposure draft released for public consultation which amends the proposed thin capitalisation changes and debt deduction creation rules.

• Promoter penalty law reform: Exposure draft released
  

  The Government is consulting on exposure draft legislation expanding the promoter penalty provisions and increasing ATO powers.

• ATO issues finalised PCG on Intangibles Migration Arrangements
  

  The ATO has released Practical Compliance Guideline 2024/1 Intangibles Migration Arrangements for immediate application, with key changes to earlier draft guidance.

• ATO finalises TR 2023/1 on residency for individuals
  

  TR 2023/1 finalises the Commissioner's view on tax residency for individuals but promised Government reform yet to come.

• New public country-by-country reporting rules
  

  Large multinationals with an Australian presence may be required to publicly report key tax information.

• Senate amendments: franked distributions funded by capital raisings
  

  MinterEllison explores the amendments to the Government's regime for making certain distributions that are funded by capital raisings unfrankable.