Jeremy Makowski

Special Counsel

Melbourne

Legal Expertise

Expertise

Prior to joining Cornwalls, Jeremy worked in the M&A (Deals) Tax department of a leading Big 4 accounting firm and has advised from both an advisory and litigation perspective. He has advised multinational corporations, superannuation funds, private equity houses and family groups.

Jeremy has also worked within state and federal government, where he issued private rulings, determined objections and advised on large infrastructure acquisitions, public private partnerships, global restructures and public listings; and has also worked on some of Australia’s largest taxation litigation cases.

Jeremy has litigated on anti-avoidance, transfer pricing and CGT-rollover, and has also conducted complex insolvency and debt recovery litigation including obtaining freezing orders (mareva injunctions) on behalf of the Deputy Commissioner. He has also advised and litigated on civil penalties, breaches of garnishee notices and director penalty notices.

Experience

Jeremy’s recent experience includes advising:

  • on the sale of the Fort Knox storage business to Blackstone;
  • on the acquisition of the Milbrae concrete, quarry, and mining services business;
  • on the establishment of an overseas financial and cryptotrading company, including the application of the ‘controlled foreign corporation’ provisions;
  • on the tax ramifications of establishing ‘asset-backed’ and ‘utility’ crypto tokens;
  • an Australian fund manager on the available concessions from and ability to utilise the Investment Manager Regime;
  • on and drafting a family agreement and related documents as part of succession planning and intergenerational asset transfer, including providing the option for family members to ‘opt out’/exit in an equitable and efficient manner;
  • on and successfully applying for a private ruling confirming the sale of business will not trigger CGT on the basis that the ‘same business test’ and ‘common ownership’ requirements are met;
  • on a group restructure, including scrip for scrip rollover;
  • Singapore Post on its acquisition of a 38% stake in Freight Management Holdings;
  • Goldman Sachs on the sale of its stake in AirTrunk to a consortium led by Macquarie Asia Infrastructure Fund 2;
  • the Future Fund on its acquisition of a 24% stake in Canberra Data Centres;
  • CUB (AbInbev) on its acquisition of Balter Brewing Company;
  • Goldman Sachs on its Series B funding for Secure Code Warrior, reported as the largest ever US investment in an Australian cybersecurity business;
  • Southern Cross Austereo on its acquisition of Redwave Media from Seven West Media;
  • the Commissioner in Victoria Power Networks Pty Ltd v Commissioner of Taxation [2019] FCA 77;
  • the Commissioner in Paule v Commissioner of Taxation [2019] FCA 394;
  • the Commissioner in Sole Luna Pty Ltd as Trustee for the PA Wade No 2 Settlement Trust v Commissioner of Taxation [2019] FCA 1195.

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Memberships And Associations

  • Law Institute of Victoria
  • Institute of Chartered Accountants

Qualifications

  • Bachelor of Commerce/Law, Monash University
  • Master of Laws, The University Of Melbourne

Jurisdictions Admitted to Practise

  • Victoria

“As a trusted advisor, I pride myself on acting with integrity and providing independent, open and honest advice that is commercial and tailored to the specific circumstances and objectives of the client.”

Tax