ATO Reviews and Audits
We act from the first notification, structuring responses to information requests, position papers and draft reasons for decision. Evidence assembled properly now can resolve a matter early or strengthen your position later.
Tax disputes and litigation.
Experience is what puts a taxpayer back in control of a tax dispute. Every dispute is shaped by evidence, procedure and judgment, and the way each is handled can materially affect the outcome.
Wolfe Kershaw Law is a dedicated tax disputes and litigation practice, providing taxpayers and their advisers with experienced representation at every stage of a dispute.
Experienced
Strategic
Decisive
Focused
Our Approach
A tax dispute is not simply a tax problem.
A tax dispute is rarely about a single issue. Most bring together technical tax questions, procedural requirements, statutory time limits and a genuine choice of pathways to resolution, each with its own risks and consequences.
We help you navigate all of this, taking account of the evidence, the strength of the technical position, where the matter sits in the dispute process and the pathway ahead of it.
That allows us to build the strongest position available, whether the right outcome is resolving the matter during audit, negotiating a settlement, succeeding at objection or taking the matter further.
Every matter is handled only by a lawyer with extensive experience in tax disputes, from the first conversation to the last.
Our Services
The full life cycle of a tax dispute.
Objections
We establish what the Commissioner's position rests on and answer it with the correct technical position, properly substantiated. The aim is to resolve the matter at objection, on grounds strong enough to carry it further if needed.
Negotiations, Dispute Resolution and Settlement
Part of running a case is judging whether negotiation, dispute resolution or settlement offers the best outcome, and when. That may mean dealing directly with the ATO, in-house facilitation, mediation or conciliation.
Tribunal and Court Litigation
An adverse objection decision may be reviewed in the Administrative Review Tribunal or appealed to the Federal Court. Decisions outside Part IVC may be challenged by judicial review. We advise on the appropriate course and conduct the litigation end to end, including any appeal.
Private Rulings
A private ruling settles how the law applies to your arrangement, for you and the ATO alike. It is an exacting instrument, and the drafting decides the protection you get. We work the issues through with the ATO and object to or litigate an adverse ruling decision.
Director Penalty Notices
A director penalty notice creates a parallel liability owed by the directors personally for the company's debt. The options available to directors are limited and the time to act is short. We examine both the notice and the underlying liability to find the best outcome.
About
Teigen Kershaw LLB, LLM, CTA
Teigen Kershaw has spent almost a decade in tax disputes and superannuation. That has included senior roles in private practice and at the Australian Taxation Office.
She has had carriage of cases across every market segment. These have involved individuals, small business, private wealth groups, large business and multinationals. The issues have spanned income tax, goods and services tax, fringe benefits tax, luxury car tax, international tax and treaties. The amount of tax in dispute has ranged from hundreds of thousands to hundreds of millions.
Her experience spans matters in the Administrative Review Tribunal (formerly the AAT), Federal Court, Full Federal Court, Supreme Courts and High Court.
As Principal of Wolfe Kershaw Law, she brings that experience to taxpayers and their advisers, working alongside them to reach the best outcome.
Cases
Reported decisions.
A selection of reported decisions in which Teigen Kershaw has acted.
Full Federal Court
AusNet Services Limited v Commissioner of Taxation
[2025] FCAFC 21
Income tax · interposition roll-over, s 615-5 ITAA 1997
For the Commissioner of Taxation
JudgmentFull Federal Court
Commissioner of Taxation v Michael John Hayes Trading Pty Ltd
[2024] FCAFC 80
Income tax · dividend stripping and franking credits, s 207-155 ITAA 1997
For the Commissioner of Taxation
JudgmentQueensland Court of Appeal
Yao v Fang
[2025] QCA 86
Civil procedure · withdrawal of admissions as to ownership of funds
For the Deputy Commissioner of Taxation
JudgmentAdministrative Appeals Tribunal
The Beneficiary and Commissioner of Taxation
[2020] AATA 3136
Income tax · disclaimer of an entitlement under a trust
For the Commissioner of Taxation
JudgmentWork Together
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