Megan Bishop Email and Phone Number

I assist private and public companies, multi-nationals, not-for-profit entities, individuals, trusts, partnerships and superannuation funds to navigate and manage complex ruling requests, risk reviews, audits and litigation.

My areas of specialization include research and development tax, trust tax issues, superannuation tax, residency and mobility issues, employment taxes, payroll tax, stamp duty, anti-avoidance measures and tax agent compliance issues.

I have been involved in some of the most precedential tax cases of the last 12 months. Highlights of my time at Holding Redlich include:

• acting for the taxpayer in JMC Pty Ltd v Commissioner of Taxation [2023] FCAFC 76: a case that held a university lecturer was engaged as a contractor not as an employee and that the employer did not have obligations to make superannuation obligations.
• acting for the taxpayer in FCT v Guardian AIT Pty Ltd ATF Australian Investment Trust [2023] FCAFC 3: which concerned the application of tax anti-avoidance measures to how trust distributions were made. It is the first case to consider section 177CB of the Income Tax Assessment Act 1936 and also precedential for what it says about Part IVA and section 100A of the Income Tax Assessment Act 1936 and their interaction and differences.
• successfully settling other litigious matters relating to research and development taxes, expenditure incurred and tax agent registration issues.

I assisted clients with their interactions with the revenue authorities and managing the dispute resolution process. I assisted through all stages of the tax lifecycle, from assisting clients to ensure their transaction is adequately documented and evidenced, to seeking private rulings, engaging in alternative dispute resolution and representing clients in Court. I acted for both individual and corporate clients across a broad spectrum of tax issues including: R&D, state taxes, employment taxes and income tax.Highlights of this period included: • an in-house secondment enabling me to see the client side experience.• acting for the taxpayer in Placer Dome Inc v Commissioner of State Revenue [2015] WASAT 141; Commissioner of State Revenue v Placer Dome Inc [2017] WASCA 165; [2018] HCA 59: Concerning the application of the West Australian land holder provisions and the valuation of land and non-land assets, including goodwill, for that purpose.• acting for the taxpayer in Satyam Computer Services Limited v FCT [2018] FCAFC 172: A special case considering the interpretation of double tax agreements and interactions with domestic laws. Considered in the context of royalties paid to an Indian resident company that are royalties deemed to have Australian source under the double tax agreement but are not otherwise royalties under Australian tax law.• Watsford v Commissioner of Taxation [2013] FCA 1389: The taxation consequences of an employee share scheme arrangement and timing issues around vesting.• successfully settling numerous income tax, R&D, residency and employment tax related disputes.

I was a Lawyer in the Business Law Department at Harwood Andrews Lawyers and was admitted to practice on 15 February 2011. My principal areas of practice included: • taxation investigation, audit and review management;• taxation dispute management including settlement negotiations and litigation;• taxation debt management including settlement negotiations and litigation;• superannuation dispute management including settlement negotiations and litigation;• taxation consultancy including in respect of income tax, capital gains tax, goods and services tax and stamp duty; • superannuation compliance consultancy including structuring limited recourse borrowing arrangements and advising on compliance concerns in relation to superannuation fund investments; and• implementation of tax sensitive commercial arrangements.I acted for individual, business and corporate clients in seeking private rulings, making voluntary disclosures, conducting audits, objecting to adverse assessments and managing debt enforcement. I gained experience in Victorian Civil and Administrative Tribunal, Administrative Appeals Tribunal, Victorian Supreme Court, Federal Court, Full Federal Court and High Court litigation. I also wrote for the Taxation in Australia Journal, including articles on Administrative Appeals Tribunal and Federal Court processes and superannuation compliance enforcement proceedings.