About Mark
Mark Macrae is a senior associate in the firm’s taxation group.
He provides technical and strategic tax advice to a range of clients including high-net-worth individuals, large private groups, public entities and not-for-profits.
Prior to joining Arnold Bloch Leibler, Mark held various positions with leading accounting firms, and was a Senior Fellow lecturing on tax avoidance in the Melbourne Law Masters program. He was appointed as a senior associate effective July 2019.
Mark is a Chartered Tax Adviser (CTA) and he is also a member of the International Fiscal Association. He holds a Bachelor of Commerce and Masters of Tax from the University of Melbourne, and a Master of Laws (Juris Doctor) from Monash University.
Practice focus
- Audits and reviews: advising clients on, and managing, all stages of ATO audits and reviews of income tax and GST matters
- Alternative dispute resolution and litigation: resolving disputes with the ATO regarding tax and administrative issues
- Voluntary disclosures and pre-lodgement reviews: advising on and managing disclosures in relation to complex tax issues to the ATO
- Income tax advice: advising on the application of income tax law in relation to general and specific anti-avoidance regimes, the debt/equity provisions, Division 7A, cross-border trust arrangements, and
- Foreign investment issues: advising on, and preparing applications under, the foreign investment regime, and advising on various State and Commonwealth surcharges and taxes imposed on foreign investors.
Experience
Mark has acted in a range of matters, including:
Corporate clients
- Ongoing significant and complex tax disputes involving representations to and appearances before the ATO’s General Anti-Avoidance Rules Panel on Part IVA issues, and settlements of long-running disputes, and
- Advising a multi-national manufacturer on tax audits and disputes regarding transfer pricing, residency, and the application of the controlled foreign companies regime.
Private clients
- Acting for large private groups to negotiate with the ATO in relation to the disposal of strategic assets
- Assisting family groups manage complex structures, including advising on family trust elections and Division 7A, and
- Pre-lodgement engagement with the ATO in relation to complex cross-border transactions.
