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TOFA for corporates - practical aspects and action plan paper

Published on 25 May 07 by NEW SOUTH WALES DIVISION, THE TAX INSTITUTE

This paper addresses how corporates should be responding to the most recently announced TOFA changes. In particular, it focusses on addressing:

  • the potential impact of these changes on key business transactions
  • the different decisions and choices taxpayers can make and what factors should be taken into account
  • development of a practical action plan in response to these proposed changes.

Author profiles

Christopher Kinsella CTA
Chris is a tax partner based in Sydney with the law firm Holding Redlich. Chris has over 30 years’ experience advising clients in relation to tax matters, particularly early ATO engagement, ATO access powers, tax audits, tax litigation and dispute resolution. Chris has acted for clients in banking/insurance, property/infrastructure, pharma, mining/energy, manufacturing and professional services. The Holding Redlich tax controversy team represents taxpayers (and their advisors) in tax disputes in both the Federal Court and the AAT. Focus areas include anti-avoidance, transfer pricing and international tax. Notable cases that Chris has been involved with include the Chevron transfer pricing case and the Resource Capital Fund tax cases. Recent topics receiving attention from clients also include legal professional privilege, promoter penalties and the ATO’s broader attitude to tax advisers more generally. Chris is the chair of the Tax Institute’s Dispute Resolution Committee and the chair of the Number One Tax Discussion Group. Chris is accredited in dispute resolution with the NSW Law Society. - Current at 14 December 2021
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Gavin Marjoram CTA
Photo of author, Gavin MARJORAM Gavin is a Partner in the Financial Services tax practice at PwC. He specialises in the taxation of financial entities and transactions and brings a detailed understanding of the practical application and operation of tax law in this area. - Current at 18 October 2013
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This was presented at Manoeuvring the Maze: Tax Forum .

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