Build a tax due-diligence issues list covering ATO audits, CGT, GST and FBT

Key facts

Human involvement
YellowClose supervision
How AI is used
Map the data-room papers to a tax DD checklist (returns, ATO audits, tax losses, CGT, GST/FBT, PE risk) and mark empty folders.
What the lawyer must review
  • Tailor the list to the target
  • Trusts: check s 100A, UPE/Div 7A after Bendel and trust losses (Div 269 ITAA 1936)
  • Companies: check cost-setting (Div 705 ITAA 1997), off-market buy-backs, loss integrity
  • Check SPA cover for each risk
  • Set the risk ratings yourself
Written for / version
Commonwealth versionCth

Rules that apply

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Who does what

Who does what
RoleWhat they do
AssistancePotential support includes identifying points for review. Confirm the tool’s capability and permitted scope.
LawyerSet the scope, supervise the work closely, verify every part relied on, resolve omissions and exceptions, and approve the exact output.

Checklist

  1. Confirm the output against the client’s instructions and the complete relevant source material, including omissions or contradictions.
  2. Resolve exceptions and record the responsible lawyer’s approval of the exact output and intended use.

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