Tax Talks

For the target audience of tax practitioners, this is densely packed with actionable technical analysis - Bendel/Division 7A implications, three practical UPE categories, degrouping arguments, and non-obvious advice like lodging nil returns to start the amendment clock. Little filler despite the 86-minute runtime.

“one of the probably best pieces of advice I could give to someone is for heaven's sake, even if you think you're a foreign resident for tax purposes, for heaven's sake, lodge your tax return”

“the range of scenarios in which a company is a better holding structure, uh, not to mention simpler for all of these reasons that we're talking about, uh, has grown substantially”

Largely practical interpretation of recent cases and legislation rather than contrarian or first-principles thinking, though there are fresh angles like the internal company-vs-trust modelling and the New Zealand tax-haven observation. Much of it is competent case commentary that experienced practitioners would find familiar.

“it's commonly known New Zealand has zero percent cgt. Um, it's a four hour flight away”

“We've done a bunch of modeling and created a couple of internal models that show the set of assumptions you have to make to now make a company a better investment vehicle under indexation”

Nick Schaefer is a genuine practitioner - partner at PGP Consulting advising private businesses, family offices and wealthy families - and the two hosts are practising tax specialists, so the discussion draws on real client experience rather than thought-leadership. Relevant and credible, though operating at a mid-market rather than large-scale level.

“partner at PGP Consulting”

“We do, yeah a lot of work with private businesses, uh, you know, emerging family offices and wealthy families. That's sort of ah, our bread and butter client”

Exceptionally concrete: exact case names, court tallies, statutory sections, dollar thresholds and dates, plus real data points like the 25% off-plan-to-SMSF stat and the $600/month disposable income figure. Very little hand-waving.

“the AAT was 2 0, the federal court was 3 0, um, and the high court was 5 2. So we've got 10, two at the end of it”

“The Australian had a stat that 25% of off the plan sales were to SMSFs”

A genuine three-way expert discussion with real follow-ups, hypotheticals and probing questions, and no PR softballs - but it is collegial agreement among peers rather than productive disagreement or pushing back on claims.

“can either of you think of any example where we've had a case that's literally lost every step of the way?”

“And they say they're adamant, they want, they, they want to, they want to not be taxed in Australia. What do you do?”