My practice is founded on providing objective advice and assessments, and I take a strategic, balanced approach to taxation matters. My clients include major listed and privately held corporations, private clients, as well as the Australian Taxation Office (ATO).

I am committed to minimising tax disputation by providing preventive tax risk management and governance solutions. I work with clients to establish efficient and cost-effective ways to resolve or manage ATO disputes.

Career highlights

• Assisted in successful resolution of a transfer pricing disputes for clients including a global Life Sciences client and a top listed Energy and Resources client.
• Assisted in successful resolution of taxation disputes for a global Energy and Resources client.
• Facilitated a successful out of court resolution of a GST related dispute for a Building and Construction client.
• Assisted in successful resolution of tax disputes involving an application of anti-avoidance provisions for several ASX listed clients in Financial Services and in Energy and Resources sectors.
• Assisted several high net worth clients to successfully navigate and resolve their taxation disputes with the ATO.
• Acted as an instructing solicitor in leading tax litigation in all relevant jurisdictions, including in Federal Court of Australia and High Court of Australia representing the Commissioner of Taxation, including most recent matters of PepsiCo v Commissioner of Taxation, Hilton Resorts v Commissioner of Taxation (decision pending), as well as Mussalli v Commissioner of Taxation, Origin Energy v Commissioner of Taxation, Sibai v Commissioner of Taxation, RCF IV/V v Commissioner of Taxation, Blank v Commissioner of Taxation, Oswal v Commissioner of Taxation and many others.
• Facilitated a successful resolution of a dispute between an ASX–listed Financial Services company and the ATO related to the consolidated group’s carry-forward losses.
• Providing ongoing assistance and representation to a large privately held group of companies in relation to GST related disputes with the ATO.
• Advised and represented several overseas based corporations in relation to the issues arising out of their acquisitions of an interest in an Australian-based resources company and an application of TARP provisions.

Education
LLM (University of Sydney); BSW/LLB (University of NSW)

• Law Society of NSW
• Tax Institute of Australia

• Federal Court's decision on awarding indemnity costs
  

  Federal Court exercises discretion to award indemnity costs in a fixed amount sought by the Commissioner of Taxation.

• Division 142 passing on clarified by the Full Court - win for the taxpayer
  

  MinterEllison are pleased to have acted for the taxpayer, Geocon whose appeal was allowed by the Full Court, providing guidance on the question of passing on under Division 142.

• Under review: the ATO's renewed focus on private groups
  

  The ATO is devoting significant resources to assuring the tax and superannuation obligations of private groups, including small to medium enterprises, family offices and high net worth individuals.

• The Superannuation Guarantee Gap
  

  On 29 August 2017, the ATO announced the results of research it conducted into 'the superannuation guarantee gap'. This superannuation guarantee gap is an estimate of the difference between the amount of superannuation guarantee contributions made and the amount of superannuation guarantee contributions required to be made.

• PepsiCo: High Court dismisses embedded royalty appeal
  

  High Court majority delivers a landmark decision that has implications for cross border arrangements involving intellectual property and diverted profits tax provisions in 4:3 majority judgment.

• Federal Court's decision in Mussalli v Commissioner of Taxation
  

  MinterEllison represented the Commissioner of Taxation in his recent successful litigation in Mussalli v Commissioner of Taxation in which the Federal Court found that payments described as "prepaid rent" and paid by a franchisee to a franchisor upon entering into lease and license agreements were capital or of a capital nature and not deductible under the Income Tax Assessment Act 1997 (Cth).