This session explores:
- Processes available for early engagement with the ATO
- The Commissioner’s power to issue different kinds of assessments (deemed, default and special assessment)
- Pros and cons of the different Part IVC review and appeal rights and other avenues such as Judicial Review
- The limited amendment period, dealing with out of time objections and reviews
- Evidence and information gathering (including expert evidence) to overcome the burden of proof in tax cases; and
- Setting the grounds of dispute, the purpose of the SFIC, and “reasonableness” in cases such as Avon Downs, and Kolotex.