B. Comm., LL. B. (Hons) Melb.
03 April 1995
Signed Bar Roll:
23 May 1996
Admitted to Practice:
Areas of Practice:
- Administrative Law
- Commercial Law
- Public Law
- Revenue & Superannuation
- Taxation Law
Fiona recently resumed full-time practice at the Victorian Bar. She is a former Deputy President of the Administrative Appeals Tribunal (2012-2017).
Her areas of practice include taxation and revenue law (federal and state), commercial law, regulatory law and administrative law, at trial and appellate level.
Fiona is a former Senior Fellow at Melbourne Law School (2002, 2004-2005). She is a member of the International Association of Tax Judges.
National Mutual Life Association of Australasia Ltd v Commissioner of State Taxation  SASC 261 (leading counsel for NMLA); on appeal (2011) 110 SASR 536 (sole counsel for NMLA); special leave application AMP Life Ltd, ANZ Life Assurance Ltd, ING Life Ltd, NMLA v Commissioner of State Taxation  HCA Trans 074 (junior counsel for the applicants) – stamp duty – insurance business – characterisation of premiums and policies;
Crown Melbourne Ltd v Commissioner of Taxation (settled in 2009) (junior counsel for Crown) – deductibility of payments of tax made to State of Victoria – Pt IVA of Income Tax Assessment Act 1936;
Commissioner of State Revenue v Challenger Property Nominees Pty Ltd  VSC 203 (junior counsel for Challenger) – duty – subscription for and redemption of units in unit trust – exemption for change in trustees – dutiable value of transferred property.
Tasman Group Services Pty Ltd v Commissioner of Taxation  FCA 23 (junior counsel for Tasman); on appeal FCT v Tasman Group Services Pty Ltd (2009) 180 FCR 128; special leave application  HCA Trans 107 – commercial debt forgiveness provisions of Income Tax Assessment Act 1936 – connection of debts held by non-resident corporation with Australia;
Caltex Australia Petroleum Pty Ltd v Commissioner of Taxation (2008) 173 FCR 359 (junior counsel for Caltex) – excise duty – petroleum products – including technical and constitutional aspects;
Academic appointments include:
Senior Fellow, Faculty of Law, University of Melbourne – Superannuation Law, Graduate Program (2002, 2004-05).
- ‘Hart’s Case – What Kind of Hand Has the High Court Dealt?’ (2004) 39 Taxation in Australia 23, co-written with J W de Wijn QC;
- ‘Part IV A – Twenty – Two Years On …. In a State of Maturity?’ (Pt 1) (2003) 38 Taxation in Australia 310; (Pt 2) (2004) 38 Taxation in Australia 372, co-written with J W de Wijn QC;
- ‘Why the Superannuation Guarantee Scheme is Unconstitutional’ (1999) 28 Australian Tax Review 13; (2000) 3 Tax Specialist 254.
From 24 July 2008:
Liability limited by a scheme approved under Professional Standards Legislation.