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Elizabeth Allen
special counsel, commercial | tax
meet Elizabethabout Elizabeth
about Elizabeth
Over 7+ years, Elizabeth (Liz) has carved a niche for herself deciphering the intricacies of Australian income tax laws and demystifying their application to clients in a way that makes sense to them.
Working predominantly with SME clients across a diverse range of industries, Liz takes pride in not only being a legal advocate for her clients but also a trusted advisor. Liz empowers clients to navigate the challenging tax landscape and gives them the knowledge needed to actively contribute to decisions that shape their businesses.
Liz also works closely with accounting practices, providing a service that bridges the gap between accounting and the law in most areas of direct taxes, including cross-border issues, internal and third-party merger and acquisitions and trusts. Her specialties lie in areas such as income tax consolidation, employee share schemes and tax effective structuring (such as retention of ABN restructures).
Liz understands the impact that tax laws can have on the livelihood of her clients. This understanding forms the core of her approach, ensuring that her guidance goes beyond tax technical answers and aligns with the real-world challenges faced by businesses. She has built her reputation as a trusted advisor within the tax industry and in 2023 was listed as the Tax Institute’s Tax Trailblazer for Queensland. Macpherson Kelley’s tax team are also listed in Doyles Guide 2023 as a Recommended Tax Law firm.
Liz is currently completing a Master of Laws (Taxation) at the University of Sydney.
“Achieving solutions for clients who are faced with complex tax needs is incredibly rewarding. Helping people through their legal challenges is a privilege.”
Areas of Expertise
- Business structuring
- Employee share schemes
- Inbound and outbound residency taxation advice
- Income tax advisory – individuals and corporate
- Income tax consolidation
- Mergers and acquisitions
- Small business capital gains tax concessions and rollovers
- State and Federal revenue office engagement – rulings, audit/objection and litigation
awards
Doyles Guide, Recommended Firm, Leading Tax Law Firms, Queensland 2023
publications
Liz is regularly approached to provide insights on her practice areas through a range of speaking opportunities. Previous and upcoming presentations include:
- Tax Institute: Income tax consolidation, Section 100A, CGT rollovers
- The Education Network: Are the ATO and Beneficiaries Putting a Blowtorch to Trustee Distribution Resolutions?
- The Education Network: Structuring and choice of entity
- QLS Symposium Panel member 2024: Corporate restructuring – taxation and duty considerations with available exemptions
Liz also frequently contributes papers and articles to the Tax Institute. Recent articles include:
leadership positions
Committee member, Asia-Pacific, Multilaw
recent experience
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Income tax disputes
Liz is currently assisting Australian and overseas clients in resisting default income tax assessments and departure prohibition orders based on primary concepts of income. One significant matter remains in progress, being the appeal of amended assessments exceeding $33 million. The matter is now awaiting judgment in the Federal Court having been heard over 7 days in late 2023. In addition to court-based matters, Liz assists taxpayers on engaging with the ATO for tax certainty through avenues such as private binding rulings, early engagement and commercial deals and the independent review procedure.
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Due diligence and structuring for M&A
Acted for Queensland’s largest privately owned and operated supplier of access hire and scissor lift hire equipment in providing the due diligence and structuring advices relating to acquiring another complementary privately owned business in North Queensland. The transaction had an estimated value of $17M and required us to work through several complexities from both tax and commercial perspectives to achieve desired result for all parties. From a tax perspective, it involved managing both rollover and arm’s length requirements, as well as tax consolidation and its interaction with the temporary full expensing measures.
