About Greg
Greg Judd is a Special Counsel in the firm’s taxation practice and advises clients on all aspects of direct taxation.
Prior to joining Arnold Bloch Leibler, Greg worked for over a decade in roles with Australia’s largest legal and accounting practices, and tutored, lectured and co-ordinated taxation at leading Australian universities.
Practice focus
Greg’s practice focuses on the following areas:
- advice in relation to investment in Australia and abroad, including:
- vehicle selection: including all types of trusts, companies and partnerships in isolation and as part of a group, presence and residency
- capital raising: including all types of debt and equity funding, ASX listing, product design and investor communications
- debt structuring: including Division 7A, debt/equity classification, thin capitalisation rules and TOFA
- operations: including intergroup and intragroup (small, SME, large and multinational) domestic and cross-border dealings
- losses and profit repatriation: including ownership, control, attribution and dividend regimes
- expansion: including organic growth, mergers and acquisitions, and
- exit/divestment, including demergers
- Taxation of trusts (including family trusts, MITs and AMITs), annual trust reviews, preparation of trust deeds and resolutions to distribute or stream income and capital
- advice in relation to succession planning
- advice to the not-for-profit sector: including status as a Deductible Gift Recipient (DGR) and Tax Concession Charity, and
- dealing with the ATO to obtain guidance (such as rulings) and to respond to complex audits and resolve disputes.
Experience
Greg has acted for both domestic and international clients in a wide range of matters, including:
- ASX listing of a number of groups, including pre-listing capital and debt restructuring
- the exit of Crown Resorts from the CrownBet joint venture, entry of The Stars Group and acquisition of William Hill Australia
- the sale of interests in a long-standing manufacturing business valued at circa A$600 million and issues relating to the crystallisation of gains in, and repatriation of profits from, multiple jurisdictions including China, Hong Kong and Australia
- the sale of interests in a circa $200 million business and issues relating to note conversion, employee share option cancellation, rollover relief, buy-back rules, earn-outs, value shifting and start-up concessions
- a company issuing shares to repay a Malaysian lender and issues relating to debt for equity swaps, commercial debt forgiveness, traditional securities, thin capitalisation, value shifting, CGT, share capital tainting and dividends funded by capital raising
- the movement of assets between foreign trusts and the transferor trust rules
- the structure of numerous investment funds, including reviewing offer documents, related documents and communications with investors. Examples include:
- product design and structure for investment by foreign life companies into US real estate via Australian superannuation funds, including requirements under the Managed Investment Trust regime and constitutional amendments to cater for the introduction of the Attribution Managed Investment Trust regime, and
- registration, reporting and compliance obligations of a venture capital fund under income tax, partnership and venture capital legislation
- the interaction between CGT, foreign realisation events and foreign currency denominated earn outs, and obtaining a private ruling regarding same
- the domestic structure of a UK entity setting up, and operating, a peer to peer lending platform in Australia
- the Australian structure of a foreign property developer, including group funding issues relating to debt and equity, thin capitalisation, loans to related parties and transfer pricing
- application of Australia’s foreign investment rules, including preparing applications to the Foreign Investment Review Board and responding to requisitions
- identification, ownership and licencing of intellectual property, and the effect of tax consolidation on that property
- rules relating to permanent establishments and withholding tax, including for taxpayers conducting major sporting events and exhibitions
- the structure and reporting obligations of private practice partnerships, including service trust arrangements, Everett assignments, small business concessions and superannuation
- DGR endorsement of an international organisation as an overseas aid fund, and drafting that organisation’s policies on project management, child protection and anti-terrorism, and
- responding to numerous ATO audits.
Directorships & memberships
Greg is a member of The Tax Institute and the International Fiscal Association.
