Fiona Dillon

Fiona Dillon, CTA, is the ATO’s Chief Tax Counsel, accountable for the ATO’s public advice and guidance, litigation, and resolving the ATO’s most significant tax technical issues.

Fiona previously served as Minister-Counsellor (Taxation) in the Australian delegation to the OECD based in Paris and spent a number of years in private practice.

Fiona is an admitted Australian legal tax practitioner and holds a Bachelor of Commerce, Bachelor of Laws with Honours and a Master of Taxation.

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Session details

SME

Session 4.1: Practical application and implications of Section 100A - Part 2

Speakers: Leanne Connor, CTA, WGC Business Advisors, Fiona Dillon, CTA, Australian Taxation Office Robyn Jacobson, CTA, The Tax Institute

The ATO’s final guidance on section 100A was released on 8 December 2022 and includes changes that incorporated feedback received during public consultation.

Using case studies, this practical session will cover:

Where we’ve landed on section 100A, more than two year-ends on from the release of the ATO’s initial draft guidance in early 2022
Falling between the zones — when your clients’ arrangements differ from the ATO examples
Loans, gifts and undrawn amounts by family members — what is needed to demonstrate the beneficiary’s entitlement has been extinguished for their own benefit?
What supporting documentation is required to explain the transactions that have happened and what is the risk of trustees recording too much?

Fiona Dillon, CTA

Session details

SME

Session 4.1: Practical application and implications of Section 100A - Part 2

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