Biography

Philip acts for a broad range of clients including corporate groups, private investors, employers, self managed superannuation funds, family offices, charities and not-for-profit entities. His clients include major infrastructure bodies such as Sydney Metro, health, educational and religious organisations, and international businesses establishing or acquiring Australian entities.

Philip advises on income tax, capital gains tax, GST and stamp duty in connection with business acquisitions and disposals, corporate and trust group restructuring, development vehicle structuring and property investment. He advises employers and self managed superannuation funds on superannuation guarantee compliance, ATO dealings and investment structures. For estate and business succession planning, Philip designs structures across superannuation, trust and corporations law with asset protection in mind. He also advises charities and not-for-profits on tax concessions and entity establishment. With over nine years at the Australian Taxation Office, he brings direct regulatory perspective to ATO engagement and dispute management.

Philip leads the firm's GST advice to Sydney Metro on complex issues arising under a major project development agreement, including timing of GST attribution, invoicing for non-monetary consideration and amendment of returns, in connection with a transaction with a total deal value in excess of $227 million. He has also advised on the structure of a US company's acquisition and financing of an Australian enterprise, on the taxation aspects of US residents establishing cross-border holding structures with Middle East operations, and on a tax-exempt organisation's acquisition of a taxable hospital-operating company.

Philip's nine years with the Australian Taxation Office give him an insider's understanding of how revenue authorities assess risk and conduct audits. With more than 30 years of practice in taxation and superannuation law, he is appointed to the ATO legal panel for taxation dispute matters, reflecting the firm's standing in contentious tax work.

Credentials

Academic qualifications:

• Master of Laws
  
• Bachelor of Laws
  
• Bachelor of Science with Honours
  

Philip's experience

Sydney Metro — GST advisory

Advising Sydney Metro on complex GST issues arising under a major project development agreement, including the implications of delayed invoicing, timing of GST attribution for Value Share Payments, and the GST treatment of non-monetary consideration under the Victoria Cross Integrated Station Development Over Station Development Project Delivery Agreement. Total deal value in excess of $227 million. Ongoing.

US company acquisition of Australian enterprise

Advising on the structure of the acquisition and financing of a US company's acquisition of an Australian enterprise, including cross-border tax and structuring considerations.

US residents — Cross-border holding structure

Advising on the taxation aspects of US residents establishing an Australian company to hold a foreign company with business activities in the Middle East.

Tax-exempt organisation — Hospital acquisition

Advising on the taxation aspects of a tax-exempt organisation acquiring a taxable company operating a hospital, including structuring to preserve concession status.

Tax-exempt entities — Revenue concessions

Advising health, educational, charitable and religious groups on obtaining federal, state and territory revenue concessions for restructuring of their tax-exempt entities and engaging with revenue authorities to secure those concessions.

Self managed superannuation funds

Advising self managed superannuation funds on investment structures, related party transactions and compliance with the superannuation guarantee regime, including dealings with the Australian Taxation Office on breaches.