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Tax Training – 26/09/2025 – Adrian Cartland: Trust Splitting PBRs and Resettlement

This session examines the ATO’s approach to trust splitting and resettlement. While the Commissioner’s outcomes in recent private rulings may be defensible, the reasoning is, in my view, wrongly framed. We will analyse the ATO’s position against the background of...

Tax Training – 19/09/2025 – Julie Van der Velde: Inadequate Deliberation and Trustee Duties

Next week Julie Van der Velde, Founder and Principal of VdV Legal, will lead our session. Julie has over 20 years’ experience in tax, trusts, and estate planning. She will examine the Privy Council’s decision in Ashley Dawson-Damer v Grampian Trust Co Ltd [2025] UKPC...

Tax Training – 12/09/2025 – Adrian Cartland: Warren Tredrea, Promissory Notes and the Limits of Payment

This session examines the Full Court’s decision in Tredders Investments Pty Ltd as trustee for Warren Tredrea Trust v Channel 9 South Australia Pty Ltd (No 3) [2025] FCAFC 125. The case is the latest in a line of authorities rejecting attempts to discharge debts...

Tax Training – 05/09/2025 – Adrian Cartland: Substratum and Trust Resettlements

This week’s session examines the Queensland Court of Appeal’s decision in Staley v Hill Family Holdings Pty Ltd [2025] QCA 95 and its implications for the concept of “substratum” in determining whether a trust variation constitutes a resettlement. The case highlights...

Tax Training – 29/08/2025 – Adrian Cartland: Stability AI, Compression v Vectorisation, and Copyright

This week we move from the Anthropic case to Andersen et al v Stability AI Ltd in the United States, a case that directly raises whether AI training involves simple “vectorisation” (statistical abstraction) or “compression” (storing compact but recognisable copies)....

Tax Training – 22/08/2025 – Adrian Cartland: Anthropic, Fair Use and the Nature of Intellectual Property

We have explored an introduction to how large language models (LLMs) function, with a particular focus on tokenization, vector representations, and the idea of whether these models truly “compress” text as part of their process. We’ll be continuing on with our...
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