Proposed Upcoming Tax Training Cases

For the past 12 months we have been on a thematic arc considering the meaning of “apply” in relation to trust income and capital. This has centred around Fischer v Nemeske Pty Ltd [2016] HCA 11 and the cases leading up to it. Prior to that the arc was on...
AI Hallucinated Citations Have Been Used In a UK Tax Case

AI Hallucinated Citations Have Been Used In a UK Tax Case

AI hallucinated citations have been used in a UK tax case. The headnotes promise a wild ride “appellant relied on case law which could not be found on any legal website – whether cases generated by artificial intelligence such as ChatGPT – yes, case law invented...
ATO Decentralised Finance And Wrapping Crypto

ATO Decentralised Finance And Wrapping Crypto

On 9th November 2023 the ATO has released web guidance in relation to decentralised finance and wrapping crypto transactions. I presented the below example over a year ago at seminars for The Tax Institute, private clients, and in submissions to Treasury. The ATO has...
ChatGPT For Lawyers

ChatGPT For Lawyers

ChatGPT For Lawyers   “The first thing we do, let’s [replace] all the lawyers” Another day, another prediction that Artificial Intelligence (“AI”), is going to replace lawyers. As a lawyer who has been building AI for nearly 10 years it seems proper...
Why I Hate Your Sub-Trust

Why I Hate Your Sub-Trust

There is a certain type of sub-trust over income that many trust deeds purport to create, and which the Federal Commissioner purports to allow. This is where a trust is established over the income distributed from another trust. This is problematic for the reasons...