Vincent Licciardi

Vincent specialises in the tax affairs of high net worth individuals, wealthy family groups and private clients. He is regularly instructed by clients who need solutions to complex tax and legal problems for their businesses and investments. In particular, with respect to:

  • Reviews, audits and litigation conducted by the Australian Taxation Office (ATO). Vincent worked for the ATO for 15 years before moving to HWL Ebsworth lawyers. His clients have access to his deep knowledge and understanding of the ATO, giving Vincent’s clients the edge in tax disputes and setting him apart from all other tax lawyers;
  • Structuring buy-side and sell-side transactions to maximise returns and reduce the risk of adverse tax consequences. Vincent also restructures private groups, trading and investment vehicles to implement families’ succession and estate plans; and
  • Tax planning strategies, complex tax advice and annual internal risk reviews. Vincent recommends that all clients invest in an annual tax compliance check-up to avoid unnecessary problems when tax regulators come knocking.

Vincent also provides his expertise directly to accountants and lawyers generally. For example, where accountants, lawyers and personal advisors are assisting their own clients with deceased estate claims and divorce proceedings.

Separately, Vincent specialises in disciplinary proceedings and investigations of tax practitioners’ personal and business affairs. Such investigations usually commence when disgruntled clients dob-in their advisor or where regulators perceive there to be problems in a practice, which may or may not exist. He focuses on matters involving the Tax Practitioners Board.

Vincent regularly presents on various issues in tax, including for the Tax Institute of Australia. Vincent publishes a monthly webinar, which is open to all clients and their advisors, and his opinion is often sought after by daily accounting and finance publications.

Experience

Vincent’s experience includes advising:

  • Wealthy family group in the construction industry, in response to ATO audit and objection claiming tax owing in excess of AUD$10 million. The ATO investigated multiple issues including Division 7A, related party transactions, market valuations, and franking credit integrity rules;
  • Private client in preparation for a management buy-out and subsequent investment by private equity. The issues included structuring incentive rights and the acquisition of shares in the bidding vehicle;
  • High net worth individual, an international businessman, in response to an ATO audit claiming tax owing of in excess of AUD$40 million. The issues related to tax residency, share trading and tax evasion;
  • Small business operator in the farming industry in response to allegations of tax evasion and under-reporting of income and GST;
  • Private client in the Administrative Appeals Tribunal to dispute ATO assessments in excess of AUD$6 million. The issues related to allegations of round-robin money transfers and default assessments;
  • Wealthy family group in respect of an application to the ATO to exercise its discretion to lodge certain rollover documents out of time. The application to the ATO was determined in the client’s favour causing in excess of AUD $150 million in assets to become pre-CGT;
  • Tax practitioner during a disciplinary proceeding and investigation in response to serious allegations of dishonesty and inflating tax refunds;
  • High net worth individual and major shareholder of an ASX listed company, by conducting annual tax risk reviews and tax planning reviews;
  • Private client in respect of the horizontal subdivision of land including air rights, and the sale of such rights to a large property developer;
  • Syndicate of wealthy family groups on the sale of their business to an ASX listed entity for in excess of AUD$35 million. Subsequently, acting for the groups during an early engagement review of the transactions by the ATO;
  • High net worth individual to restructure the implementation of a testator’s family maintenance claim, including ensuring that lending covenants were not breached. The tax issues involved family trust and interposed entity elections for various testamentary trusts; and
  • Tax practitioner during a disciplinary proceeding and investigation in response to allegations of non-compliance with their personal and business tax obligations.

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