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Dealing with the dispute from the beginning paper
Published on 31 Jul 19 by NEW SOUTH WALES DIVISION, THE TAX INSTITUTE
This paper covers:
- evidentiary burden
- voluntary disclosures
- amendment periods
- objecting against your own assessment
- penalties, including safe harbour
- debt management.
Author profiles
Eddy Moussa
Eddy Moussa, CTA, is a practising tax lawyer with over 20 years experience in providing legal advice on taxation matters. He is a Senior Partner in the PwC Tax Controversy team. He provides legal advice to mainly multinational clients on taxation matters (including anti-avoidance), and supports clients in resolving disputes with the Australian Taxation Office. This work involves assisting clients under audit or investigation. Eddy also leads alternative dispute resolution processes, (including independent review and GAAR panel processes), briefs counsel and provides client support on anti-avoidance matters. Eddy has also advised a number of multinational organisations on audit issues involving international tax matters, cash repatriation, investment structuring, withholding taxes and treaty issues. Eddy also has an interest in the taxation of intellectual property and the anti-avoidance provisions in Australia and has written numerous papers on the topic. Eddy is a member of the National Council of The Tax Institute and also a member of the NSW State Council. - Current at 08 March 2023Andrew Howell
Andrew is a lawyer specialising in tax controversy, dispute resolution and risk management. Prior joining PwC, he worked at the ATO in audit and litigation roles. Andrew has assisted clients all over Australia, recently returning to Sydney after spending more than 3 years in Perth with PwC. Andrew has been involved in a number of litigation matters in the AAT and Federal Court and is currently advising clients in respect of compliance activities and disputes with government agencies, including the ATO. - Current at 18 June 2019
This was presented at NSW Tax Disputes Conference .
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The ATO as regulator:20 years of regulating the SMSF sector
Author(s): Jenny LinMaterials from this session:
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Dealing with the dispute from the beginning
Author(s): Eddy MOUSSA, Andrew HowellMaterials from this session:
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Resolving R&D disputes
Author(s): Hugh PAYNTER, Brock GunthorpeMaterials from this session:
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Tax disputes landscape
Author(s): Chris PEADONMaterials from this session:
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Tax debt recovery powers and the ATO
Author(s): Lucy McGovern, Keith SwanMaterials from this session:
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Independent review/alternative dispute resolution
Author(s): Jeremy GEALEMaterials from this session:
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