Tax Archives with Fletch and Sarah

HLS Tax Law
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Unlocking the secrets of Australian tax law Step inside the Tax Archives with Fletch and Sarah - where Fletch Heinemann and Sarah Lancaster delve into a treasure trove of tax issues. Some are hot off the press, others need dusting off, but all are relevant to anyone intrigued by tax and keen to discover more. 

Episodes

  1. 2026 new year resolutions: what did we learn from tax disputes in 2025?

    FEB 4

    2026 new year resolutions: what did we learn from tax disputes in 2025?

    In their first episode for 2026, Fletch and Sarah reflect on key lessons from 2025 and suggest the resolutions advisers should be taking into the year ahead. From documentation no-no’s to the 45-day holding rule for bucket companies, they break down how these issues may impact decisions and actions in 2026.

    28 min

  2. 11/25/2025

    From ordinary to anti-avoidance: the power of Part IVA

    Let’s talk about Part IVA — where is the line between tax avoidance and ordinary tax planning? In this episode, Fletch and Sarah break down the elements of Part IVA, current risks and lessons from recent cases.

    35 min
  3. Taxing distributions from foreign trusts: the Section 99B trap

    11/05/2025

    Taxing distributions from foreign trusts: the Section 99B trap

    In this episode, Fletch and Sarah cross borders to expose one of Australian tax’s stealthiest provisions — section 99B — where what seems like a harmless capital payment from a foreign trust can quickly become assessable income for an Australian resident beneficiary. We unpack how sections 99B and 99C operate, when the Commissioner steps in, and why tracing the true source of funds is key to staying out of trouble. Along the way, we share practical tips for identifying amounts of corpus and the Commissioner’s current compliance approach to 99B.

    45 min
  4. Fraud, evasion and the long arm of the Commissioner: inside Kirtlan v Commissioner of Taxation

    10/16/2025

    Fraud, evasion and the long arm of the Commissioner: inside Kirtlan v Commissioner of Taxation

    In this episode, Fletch and Sarah tackle one of the most loaded words in tax — evasion. They break down the differences between tax evasion and tax avoidance, and how these concepts often play out in audits, objections, and litigation. Sarah shares her insider view in Kirtlan v Commissioner of Taxation, while Fletch dusts off the century-old Denver Chemical Manufacturing case, which still shapes how we think about tax evasion today. Listen now.

    35 min
  5. Licence to deduct: SNA Group v Commissioner of Taxation

    09/24/2025

    Licence to deduct: SNA Group v Commissioner of Taxation

    In this episode, Fletch and Sarah go undercover in SNA Group v Commissioner of Taxation (currently subject to appeal), investigating high-stakes service entity arrangements, and whether payments to related entities within the Coronis real estate group were deductible.

    35 min
  • 5 Episodes

About

Unlocking the secrets of Australian tax law Step inside the Tax Archives with Fletch and Sarah - where Fletch Heinemann and Sarah Lancaster delve into a treasure trove of tax issues. Some are hot off the press, others need dusting off, but all are relevant to anyone intrigued by tax and keen to discover more. 

Information