The September episode of Tax Talks sees Andrew Henshaw and Rajan Verma joined by Karen Goodfellow of Goodfellow Tax Advisory to unpack the major Australian tax developments from September 2026.
The discussion begins with the exposure draft package for the proposed 30% minimum tax on discretionary trusts. The panel examines which trusts and income streams may fall outside the regime, the proposed broader definition of a fixed trust, the treatment of company beneficiaries and the complexity of adding a minimum tax framework on top of the existing trust tax rules.
The episode then turns to the proposed election allowing existing trusts to avoid the minimum tax by fixing future income and capital distributions. The panel considers the consequences of making an irrevocable election, including changes in family circumstances, corporate beneficiaries, charitable distributions, asset protection, family law and succession planning. They also review the proposed trust restructure rollover, including its all-assets approach, duty concerns and the risks of moving assets into a company.
The panel also examines the proposed innovative business CGT concession, including the holding period, registration process, Australian activity requirements, excluded industries and the challenge of maintaining eligibility through to a future CGT event.
The cases section covers the Hilton Hotels Part IVA decision and what it may mean for restructures undertaken before a sale, contemporaneous documentation and how far the ATO may look back when identifying a broader scheme. The episode concludes with a recent tax residency decision involving an engineer working in Dubai, highlighting the difficulty of severing Australian tax residency, the importance of establishing a permanent place of abode overseas and the potential CGT consequences of leaving Australia.
Across these topics, the panel returns to a practical message for accountants and advisers: understand the proposals, identify affected clients and preserve the evidence supporting important decisions, but avoid taking irreversible steps while the law remains unsettled.

The September episode of Tax Talks sees Andrew Henshaw and Rajan Verma joined by Karen Goodfellow of Goodfellow Tax Advisory to unpack the major Australian tax developments from September 2026. The discussion begins with the exposure draft package for the proposed 30% minimum tax on discretionary trusts. The panel examines which trusts and income streams may fall outside the regime, the proposed broader definition of a fixed trust, the treatment of company beneficiaries and the complexity of adding a minimum tax framework on top of the existing trust tax rules. The episode then turns to the proposed election allowing existing trusts to avoid the minimum tax by fixing future income and capital distributions. The panel considers the consequences of making an irrevocable election, including changes in family circumstances, corporate beneficiaries, charitable distributions, asset protection, family law and succession planning. They also review the proposed trust restructure rollover, including its all-assets approach, duty concerns and the risks of moving assets into a company. The panel also examines the proposed innovative business CGT concession, including the holding period, registration process, Australian activity requirements, excluded industries and the challenge of maintaining eligibility through to a future CGT event. The cases section covers the Hilton Hotels Part IVA decision and what it may mean for restructures undertaken before a sale, contemporaneous documentation and how far the ATO may look back when identifying a broader scheme. The episode concludes with a recent tax residency decision involving an engineer working in Dubai, highlighting the difficulty of severing Australian tax residency, the importance of establishing a permanent place of abode overseas and the potential CGT consequences of leaving Australia. Across these topics, the panel returns to a practical message for accountants and advisers: understand the proposals, identify affected clients and preserve the evidence supporting important decisions, but avoid taking irreversible steps while the law remains unsettled.

September Updates

Episode 5 of Tax Talks sees Andrew Henshaw and guest co-host Ani Tuna joined by Vincent Licciardi from HWLE to unpack the major tax developments from August 2026.
The discussion begins with increasing scrutiny from the ATO and Tax Practitioners Board, exploring disclosure obligations, annual registration renewals and fit and proper person requirements. The panel examines the Free decision and the risks practitioners face when outstanding tax obligations or adverse findings remain undisclosed, including where the underlying matters are disputed.
The episode then examines the second tranche of draft CGT and negative gearing measures, analysing valuation challenges, main residence issues, small business concessions and the proposed definition of a new residential dwelling. The discussion also considers foreign resident CGT reforms and changes to SMSF limited recourse borrowing arrangements, including transitional contracts, business real property and refinancing.
The panel reviews recent Victorian and New South Wales state tax cases involving windfall gains tax, property nominations and landholder duty, highlighting how contract dates and transaction sequencing can produce unexpected liabilities. The discussion also explores engagement scope, client expectations and the risks for accountants advising outside their areas of expertise.
The episode concludes with GST credits on legal and litigation costs, developments concerning Bitcoin and draft ATO guidance on crypto transactions, and the Division 293 consequences of receiving employment income in arrears. Across these topics, the panel highlights the importance of precise timing, supporting evidence and identifying risks before transactions proceed.

Episode 5 of Tax Talks sees Andrew Henshaw and guest co-host Ani Tuna joined by Vincent Licciardi from HWLE to unpack the major tax developments from August 2026. The discussion begins with increasing scrutiny from the ATO and Tax Practitioners Board, exploring disclosure obligations, annual registration renewals and fit and proper person requirements. The panel examines the Free decision and the risks practitioners face when outstanding tax obligations or adverse findings remain undisclosed, including where the underlying matters are disputed. The episode then examines the second tranche of draft CGT and negative gearing measures, analysing valuation challenges, main residence issues, small business concessions and the proposed definition of a new residential dwelling. The discussion also considers foreign resident CGT reforms and changes to SMSF limited recourse borrowing arrangements, including transitional contracts, business real property and refinancing. The panel reviews recent Victorian and New South Wales state tax cases involving windfall gains tax, property nominations and landholder duty, highlighting how contract dates and transaction sequencing can produce unexpected liabilities. The discussion also explores engagement scope, client expectations and the risks for accountants advising outside their areas of expertise. The episode concludes with GST credits on legal and litigation costs, developments concerning Bitcoin and draft ATO guidance on crypto transactions, and the Division 293 consequences of receiving employment income in arrears. Across these topics, the panel highlights the importance of precise timing, supporting evidence and identifying risks before transactions proceed.

Episode 5 of Tax Talks sees Andrew Henshaw and guest co-host Ani Tuna joined by Vincent Licciardi from HWLE to unpack the major tax developments from August 2026.
The discussion begins with increasing scrutiny from the ATO and Tax Practitioners Board, exploring disclosure obligations, annual registration renewals and fit and proper person requirements. The panel examines the Free decision and the risks practitioners face when outstanding tax obligations or adverse findings remain undisclosed, including where the underlying matters are disputed.
The episode then examines the second tranche of draft CGT and negative gearing measures, analysing valuation challenges, main residence issues, small business concessions and the proposed definition of a new residential dwelling. The discussion also considers foreign resident CGT reforms and changes to SMSF limited recourse borrowing arrangements, including transitional contracts, business real property and refinancing.
The panel reviews recent Victorian and New South Wales state tax cases involving windfall gains tax, property nominations and landholder duty, highlighting how contract dates and transaction sequencing can produce unexpected liabilities. The discussion also explores engagement scope, client expectations and the risks for accountants advising outside their areas of expertise.
The episode concludes with GST credits on legal and litigation costs, developments concerning Bitcoin and draft ATO guidance on crypto transactions, and the Division 293 consequences of receiving employment income in arrears. Across these topics, the panel highlights the importance of precise timing, supporting evidence and identifying risks before transactions proceed.

August Updates

Child support lump sum payments are often favoured by mothers and might improve the relationship between parents.

Child support lump sum payments are often favoured by mothers and might improve the relationship between parents.

391 | Child Support Lump Sum Payments

Child support non-agency payments are payments to third parties credited to a child support liability.

Child support non-agency payments are payments to third parties credited to a child support liability.

390 | Child Support Non Agency Payments

In some ways CATS Accountants is just a normal practice with a turnover of $1m. But in other ways they are quite unique and unusual.

282 | CATS Accountants

Here is an unfair contract case study to show you how the unfair contract term provisions work.

Here is an unfair contract case study to show you how the unfair contract term provisions work.

303 | Unfair Contract Case Study

The unfair contract term provisions might help you to get out of an unfair contract.

The unfair contract term provisions might help you to get out of an unfair contract.

302 | Unfair Contract Terms

Do the PSI rules apply to you? The answer can cost or save you tax.

Do the PSI rules apply to you? The answer can cost or save you tax.

301 | PSI Rules

The history of PSI is a long road through court and ATO rulings as well as the Ralph Review until we finally got some legislation.

The history of PSI is a long road through court and ATO rulings as well as the Ralph Review until we finally got some legislation.

300 | The History of PSI

What changed on 1 July 2021? No rock the boat changes but still important to know. Here are 11 changes to look out for.

What changed on 1 July 2021? No rock the boat changes but still important to know. Here are 11 changes to look out for.

Update 27 | What changed on 1 July 2021

The CGT treatment of pre-CGT shares and company assets keeps causing confusion, so here is a handy overview.

The CGT treatment of pre-CGT shares and company assets keeps causing confusion, so here is a handy overview.

299 | Pre-CGT Shares and Company Assets

When you structure a farming business, there are many factors to consider. Asset protection, flexible timing of distribution, income tax, capital gains tax. Tara Cuddihy of PWC will share some great insights with you in this episode.

When you structure a farming business, there are many factors to consider. Asset protection, flexible timing of distribution, income tax, capital gains tax. Tara Cuddihy of PWC will share some great insights with you in this episode.

298 | Structure a Farming Business

Andrew Hunzicker of Dope CFO will discuss with you how we as accountants can assist this emerging or already booming industry - emerging or booming depending on which state and country you look at.

Andrew Hunzicker of Dope CFO will discuss with you how we as accountants can assist this emerging or already booming industry - emerging or booming depending on which state and country you look at.

297 | Accountants in the Cannabis Industry

The Australian cannabis industry is highly regulated but an emerging market with huge opportunities.

The Australian cannabis industry is highly regulated but an emerging market with huge opportunities.

296 | Australian Cannabis Industry

Farm succession is all about avoiding surprises. And you do that by dealing with it during your lifetime.

Farm succession is all about avoiding surprises. And you do that by dealing with it during your lifetime.

Share Tax Talks

Sign up to save your podcasts

Tax Talks

Tax Talks episodes

About Tax Talks

Best of Tax Talks

More shows like Tax Talks

How Do They Afford That?