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Back to basics on non-resident capital gains and related developments paper


This paper covers:

  • the role of Division 855
  • how it works
  • comparison with state and territory landholder duty
  • treaty issues that arise
  • new foreign investment Review Board tax conditions
  • new non-resident CGT withholding rules - the impact on transactions.

Author profiles

Philip Bisset CTA
Philip Bisset, CTA, is a taxation partner at Clayton Utz. He has over 30 years' experience in many facets of revenue law and commercial taxation, practising as a lawyer, chartered accountant and corporate tax manager. He has significant experience in managing audit and tax disputes and in negotiating settlements to successful outcomes. Philip also helps his clients develop robust tax policies and risk guidelines to minimise the potential reputational and commercial threats to their organisations in connection with tax audits and disputes. Philip is the instructing solicitor for a number of cases currently before the Federal Court. - Current at 29 April 2021
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John Middleton CTA
John Middleton, CTA is part of the ATO’s Tax Counsel Network, where he works on complex technical advice, tax reform projects, and strategic litigation. Prior to this, he had over 20 years in the private sector as Special Counsel at Clayton Utz Brisbane specialising in revenue and commercial law. He practised in CGT, stamp duty, GST and general tax. While in private practice he was listed in Doyle’s and Best Lawyers in respect of tax matters. - Current at 16 July 2020
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Melanie McComb
Luke Furness
Luke Furness is a Senior Associate at Clayton Utz with significant experience in many types of disputes including tax and duties litigation. He has acted in a number of high profile tax and duty disputes in the Federal Court, High Court and QCAT. He also holds a Masters of Law from the University of Sydney with a focus on tax law and statutory interpretation and is a former finalist in the Lawyers Weekly 30 Under 30 Awards for Dispute Resolution. - Current at 29 April 2021
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This was presented at 2016 National Resources Conference .

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Individual sessions

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