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Published
Articles, papers and commentary
Published analysis in Thomson Reuters Weekly Tax Bulletin, Accountants Daily, Accounting Times and The Tax Institute’s journals and conferences.
2026
Bylined article
$253,055 on an unsigned draft: the limits of s 12(4)(b) of the NSW Duties Act
Thomson Reuters Weekly Tax Bulletin · Issue 29, item [560] — practitioner article · Norton & Quay Tax Law
Forever Grateful Holdings Pty Ltd v Chief Commissioner of State Revenue [2026] NSWSC 761. Uploading an unexecuted draft transfer to the Revenue NSW eDuties portal does not crystallise a duty liability. A $253,055 assessment on a routine trustee change was revoked; the correct duty was $100.
Subscription publication — no public link.
Bylined article
When should an appellate court disbelieve witnesses it never saw?
Accountants Daily · Opinion · Norton & Quay Tax Law
Commissioner of Taxation v Cheung [2026] FCAFC 75. When an appellate court may overturn a trial judge’s credibility findings, where the documentary record contradicts the oral evidence.
Paper & presentation
Year-end trustee resolutions
The Tax Institute · NSW Tax Forum 2026, session 12A — paper and presentation · Norton & Quay Tax Law
What the deed actually requires before 30 June, the mechanics of creating a valid present entitlement, and where resolutions most often fail.
Bylined article
Home office occupancy expenses after Hall: is it time to rethink the essential character test?
Accounting Times · Opinion · Norton & Quay Tax Law
Commissioner of Taxation v Hall [2026] FCAFC 43. Employees cannot deduct occupancy expenses for a dedicated home office even where they were required to work from home — and why the Full Court’s reasoning reads as an invitation to revisit the test.
Expert commentary
Qld real estate group misses out on millions in ‘service fee’ deductions
Accountants Daily · Expert commentary
Commissioner of Taxation v S.N.A Group Pty Ltd [2026] FCAFC 10. Informal intra-group service fee arrangements are not legally binding contracts, and the consequences for family businesses that operate on a handshake.
Bylined article
Can the ATO settle a tax dispute and ignore the settlement?
Accountants Daily · Opinion
Ziegler v Commissioner of Taxation [2025] FCAFC 168. Settlement deeds operate in the contractual sphere and do not constrain the Commissioner’s statutory power to assess.
2025
Expert commentary
Trusts here to stay despite mounting complexities
Accountants Daily & Accounting Times · Expert commentary
Reporting from the NSW Tax Forum session on the continuing role of trusts in private groups despite compounding compliance complexity.
Co-authored paper
The use of trusts in the 21st century — is the complexity worth it?
The Tax Institute · NSW Tax Forum 2025, session 5A — paper and presentation
Discretionary, unit, hybrid and public trading trusts; sections 99B and 100A; the Bendel litigation; and the debt deduction creation rules as they apply to closely held trusts.
Co-authored with Craig Marston CTA.
2023
Bylined article
Restructuring using roll-overs
The Tax Specialist · Cover article
A practical guide to the existing CGT restructure roll-overs and how they interact, written against the Board of Taxation’s proposed principles-based reform.
Paper & presentation
Restructures
The Tax Institute · Regional Masterclass — paper and presentation
Subdivisions 122-A and 122-B, Subdivision 124-M, Division 124-N, Division 126-G and Division 615 — and how to sequence them.
Elsewhere
Profiles
Shorter analysis of recent decisions is published on the insights page, and practical notes for advisers are collected in the fact sheets.
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