The International Academy of Estate and Trust Law


Roster

The Honourable Ian Vitaly Gzell AM QC


The Astor
123 Macquarie Street
Sydney, New South Wales 2000
AUSTRALIA

Phone: 61 423 825 310
Fax:
Email: ivsrg@ozemail.com.au

Degrees

BA (Hons), LLB, BCom, LTCL,

Membership of Professional Bodies

Fellow of Australian Society of Certified Practising Accountants

Fellow of Taxation Institute of Australia

Fellow of Australian Institute of Company Directors

Practice

Ian Gzell has practised as a barrister since 1965 and as a Queen's Counsel since 1977. He is admitted in all States and Territories in Australia, in New Zealand and in Papua New Guinea. He has also been admitted in Singapore, Fiji and Solomon Islands for individual causes. Ian specialises in revenue law with particular emphasis on international aspects. His areas of interest include planning structures for inbound and outbound investment, for both corporate and individual clients, wealth protection for individual clients including onshore and offshore superannuation and life insurance and controlled foreign corporation and foreign investment fund planning.

Practice Organisations

Editorial Board of LBC Australian Tax Practice, Advisory Board of CCH Journal of Australian Taxation, Taxation Committee of Law Council of Australia, Board of Counsel's Chambers Limited (New South Wales), former President of The Taxation Institute of Australia, former President of the Commercial Law Association of Australia, former Governor of Australian Tax Research Foundation, former board member of Barristers' Superannuation Pty Ltd (New South Wales), former secretary and treasurer of the Bar Association (Queensland), former director and secretary of Barristers Chambers Limited (Queensland), former member of Barristers Board (Queensland), former Revenue Law Editor of The Australian Law Journal.

Educational and Cultural Organisations

President of Regional Arts New South Wales, Chairman of Australia Ensemble Resources Committee, former Chairman of Queensland Theatre Company, former Chairman of Queensland Philharmonic Orchestra, former board member of Lyric Opera of Queensland, former board member of Queensland Symphony Orchestra, former part time Commissioner of Commonwealth Tertiary Education Commission, former member of Planning and Finance Committee for Queensland of Commonwealth Schools' Commission.

Published Articles

'Treaty Shopping in Australia', International Bureau of Fiscal Documentation Bulletin, Vol 52 No 12, December 1998, p 528

'Treaty Shopping', Australian Tax Review, Vol 27 No 2, June 1998, p 65

'Residence and Permanent Establishments', Taxation Institute of Australia, 1997-98 Convention Papers, Vol 1, p 20

'Impact of the Spotless and Peabody Decisions', Taxation Institute of Australia, 1996-97 Convention Papers, Vol 2, p 569

'Section 51 - Have the Goalposts Stopped Moving?', Taxation Institute of Australia, 1996 South Australian Convention Papers, p 3

'Allowable Deductions: The Coles Myer and Fletcher Decisions', Taxation in Australia, Vol 28 No 5, November 1993, p 275

'Proposed Corporate Law Changes - Do They Go Too Far?', Commercial Law Quarterly, Vol 11 No 1, September 1993, p 13

'Yesterday, Today and Tomorrow', Taxation Institute of Australia, 1993 National Convention Papers, p 5

'Liability of Directors for Fiscal Imposts on Companies', Commercial Law Quarterly, Vol 1 No 3, March 1993, p 13

'Double Talk: Emerging Trends in Tax Treaties', Taxation Institute of Australia, 1992 New South Wales Intensive Seminar Papers, p 66

'The Year in Review', Taxation Institute of Australia, 1991 New South Wales Convention Papers, p 5

'The Controversial Tax Issues Involving Interest', Taxation Institute of Australia, 1990 Victorian Convention Papers, p 22

'The Concept of Income', Taxation Institute of Australia, 1990 Queensland Convention Papers, p 1

'The Resolution of Taxation Disputes', Taxation Institute of Australia, 1988 National Convention Papers, p 99

'Capital gains - Current Issues', Taxation in Australia, Vol 22 No 5, November 1987, p 299

'The Effect of Imputation on Investment Into and Out of Australia', Taxation in Australia, Vol 22 No 4, October 1987, p 224

'Foreign Tax Credits', Taxation in Australia, Vol 22 No 2, August 1987, p 46

'Capital Gains Tax - Current Issues', Taxation Institute of Australia, 1987 Queensland Convention Papers, p 1

Opening and Closing Speeches, Taxation Institute of Australia, 1986 National Convention Papers, pp 2, 82

'Administrative Law Remedies', Taxation in Australia, Vol 20 No 6, December 1985, p 358

'Doctrine of Fiscal Nullity and its Application in the Australian Context', Taxation Institute of Australia, 1984 Victorian Convention Papers, p1

'Contesting a Trust Strip Assessment', Taxation Institute of Australia, 1984 Western Australian Convention Papers, p115

'The Tax Adviser's Responsibilities and Potential Liabilities to the Crown', Taxation Institute of Australia, 1983 New South Wales Convention Papers, p 65

'Taxation in the Eighties', Taxation in Australia, Vol 15, September 1980, p 169

'Income Tax Planning in a Gift and Death Duty Free State', Taxation Institute of Australia, 1980 South Australian Convention Papers, p 28

'Taxation in the Eighties', Taxation Institute of Australia, 1980 Queensland Convention Papers, p 46

'The 1979 Stamp Act Amendment Act (Queensland)', Taxation in Australia, Vol 14, September 1979, p 273

'Gift Duty Implications in Estate and Tax Planning', Taxation Institute of Australia, 1975 Queensland Convention Papers, p 25

'Income Tax in 1973. Commentary', Taxation Institute of Australia, 1973 Queensland Convention Papers, p 15

 

Unpublished Conference Papers

International Treaty Shopping’, Taxation Institute of Australia Seminar, Brisbane, 23 July 1999

'The Business Profits Article and Capital Gains - Commentary', International Fiscal Association, Sydney, Melbourne, 3, 5 May 1999

'Treaty-Shopping', Australian Taxation Office, Large Business and International Tax Technical Conference, Sydney, Melbourne, 16, 30 March 1999

'Treaty Shopping and Part IVA', Taxation Institute of Australia, International Tax Masterclass, Sydney, 20 October 1998

'Treaty-Shopping', Gunn Club Tax Discussion Group, Sydney, 11 March 1998

'Treaty Shopping and Part IVA', Taxation Institute of Australia International Tax Masterclass, Melbourne, 27 February 1998

'Corporate Re-organisations and Anti-avoidance Provisions', Taxation Institute of Australia Intensive Seminar, Terrigal, 13 November 1997

'"Lamesa" - Observations and Implications', International Fiscal Association, Sydney, Melbourne, 10, 12 November 1997

'The Complexity and Uncertainty of our Income Tax Structure: Calls for Change', Keynote Address, University of New England, 15 October 1997

'The Corporate Law Economic Reform Program and the Second Corporate Law Simplification Bill', Society of CPAs Seminar, Armidale, 14 October 1997

'Would a stronger Part IVA lead to a reduced need for retrospective legislation? - Commentary', Business Law Section, Law Council of Australia Taxation Law Workshop, Melbourne, 15 February 1997

'Corporate Law Changes - Do the Proposed Legislative Changes go too Far?', Taxation Institute of Australia Intensive Seminar, Terrigal, 15 November 1996

'Placer Pacific - Deductions After Cessation of Business', Ratcliffe Tax Discussion Group, Sydney, 18 November 1996

'Section 46D Margin Lending - Loans or Dividends? Part IVA', Leo Cussen Institute Seminar, Melbourne, 19 October 1996

'Concepts of Residence and Source into the 21st Century', Taxation Institute Of Australia Intensive Retreat, Melbourne, 14 June 1996

'Placer Pacific - Deductions After Cessation of Business', Taxation Institute of Australia Seminar, Sydney, 7 May 1996

'Transfer Pricing - A Practical Perspective', Deloitte Touche Tohmatsu Conference, Sydney, 30 April 1996

'Capital/Revenue Distinction of Investments of Insurance Companies and Their Subsidiary Companies', Center for Tax Education and Research, Australasia Conference on Insurance Taxation, Sydney, 19 September 1995

'Tax Planning Opportunities in the Indian Ocean Rim - Australasia: Realities and Prospects' Mauritius Offshore Business Activities Authority Meeting, Mauritius, 12 September 1995

'Routes for Direct Investment into Australasia', International Tax Planning Association Conference, Bangkok, 13 February 1995

'The Proposed APA Regime - Some Underlying Problems', Gunn Club Tax Discussion Group, Sydney, 9 November 1994

'Treaties, Competent Authority and APAs', Taxation Institute of Australia Specialist Retreat, Hunter Valley, 2 September 1994

'Company Tax Debts', CCH Directors Seminar, Sydney, 24 February 1994

'Dynamite for Directors', Commercial Law Association Seminar, Brisbane, 10 September 1993

'Allowable Deductions', Taxation Institute of Australia Seminar, Brisbane, 9 September 1993

'Dealings In Intellectual Property', Mallesons Stephen Jaques Stamp Duty Seminar, Sydney, 13 July 1993

'Liability of Directors for Fiscal Imposts on Companies', Company Law Discussion Group, Sydney, 30 June 1993

'Part IVA - The Erosion of Choice', Chartered Institute of Accountants Seminar of Excellence, Sydney, 29 April 1993

'The Effects of the Tax Treaties on Australia's Ability to Tax Capital Gains Derived by Non-residents Relating to "Australian Situated Assets"', Business Law Education Centre CGT Masterclass, Melbourne, Sydney, 5, 10 March 1993

'Thiel's Case Reviewed', Business Law Education Centre CGT Masterclass, Melbourne, Sydney, 5, 10 March 1993

'Judge Made Law', Challis Tax Discussion Group, Sydney, 26 November 1992

'Leasing And Franchising Strategies', Property Taxation Conference, Brisbane, Sydney, Melbourne, 28, 29 April, 5 May 1992

''Interest-Free Loans with Non-Residents'', One of Seventy One Tax Discussion Group, Sydney, 16 March 1992

''Interest-Free Loans with Non-Residents'', Gunn Club Tax Discussion Group, Sydney, 12 February 1992

''Domestic Law Interpretation in International Contexts'', New Phillip Tax Discussion Group, Sydney, 21 November 1991

'The Liability Of Directors For Fiscal Imposts On Companies', Master Class Legal Education Symposium, Hamilton Island, 10 October 1991

'The Implications of Thiel's Case', International Fiscal Association, Sydney, 22 August 1991

'A Review of Section 51(1)', KPMG Peat Marwick National Tax Managers' Conference, Sydney, 18 April 1991

'Current Issues with Double Tax Treaties', Business Law Education Centre Symposium, Melbourne, Sydney, 5, 13 March 1991

'Review Of Case Law on S160M(6) & (7) Covenants, Releases of Debts', Taxation Institute of Australia Twilight Lecture Series, Sydney, 25 February 1991

'How To Minimise Stamp Duty On Secured Financing Arrangements', Institute For International Research Group Seminar, Brisbane, 6 November 1990

'The Terrible Twins - Sections 160M(6) and 160M(7)', Taxation Institute of Australia Capital Gains Tax Intensive Seminar, Brisbane, 1 March 1988

'Case Study On Double Tax Treaty Issues', Business Law Education Centre Symposium, Sydney, 7 March 1986

'Objections and Beyond', Taxation Institute of Australia Convention, Darwin, 18 July 1985



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