Doctor John Azzi

Senior Lecturer, School of Law
SJD (Syd) LLB (Syd), BEc (Syd)

Biography

Dr John Azzi joined the University of Western Sydney in July 2010 after having practised as a barrister in Sydney for almost 10 years. Prior to that, John taught tax law in Australia (UNSW and UWS, 1993-1995), Switzerland (Robert Kennedy College, 1998-2004) and Holland (International Tax Academy, 1996-1998). Dr Azzi has also presented papers at important international inter-disciplinary conferences.

John has considerable professional experience having worked as an income and capital gains tax adviser with Deloittes, Sydney, as a Senior Research Associate with the International Bureau of Fiscal Documentation (IBFD) in Amsterdam (with responsibility for the Oceania countries) and as a consultant with the Australian Taxation Office, where he also was a member of the ATO Litigation Panel.

In 1997 John obtained a doctor of juridical studies (SJD) from the University of Sydney. His thesis compared the operation of Australia’s newly introduced controlled foreign company (CFC) tax regime with the US and New Zealand equivalents.

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Areas of Research / Teaching Expertise

Administrative Law
International Taxation
Tax Law & Policy
Anti-tax deferral regimes
Corporations Law
Corporate Social Responsibility
Constitutional Law
Bankruptcy
Trade Practices
Professional negligence

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Selected Publications

"Companies (NSW) Code - S 129 and Its Deficiencies” (1988) Commercial Law Quarterly 25-30

"Capital Gains Tax and Partnerships: A New Direction” (1988) Taxation in Australia 107-111

"Assignments of Partnership Income”, Australian Tax Review 262-275

"Companies Codes and the Corporations Act - Constitutional Issues”, (1989) Commercial Law Quarterly 12-14

"Restitution: Recovery of Benefits Conferred Under a Partially Performed Contract”, (1990) Australian Law Journal 630-649

"Disclosure in Prospectuses", (1991) Company & Securities Law Journal 205-234

"Forgiveness of Debt A Windfall to the Borrower", (1993) Taxation in Australia 774-781

“Policy Considerations in the Taxation of Foreign Source Income”, (1993) Bulletin for International Fiscal Documentation 547-569

"The Timor Gap Treaty", (co-authored with Jennifer Feller) Australian Tax Practice: International Tax Agreements (Loose-leaf, 1993), 4471-4492

"Historical Development of Australia's International Taxation Rules", (1994) Melbourne University Law Review 793-813

"Heritage Conservation Rebates", Australian Tax Practice: Vol. 7 (Butterworths, loose-leaf, 1994), (55 pages)

"Proposed Amendments to Controlled Foreign Corporation Rules", (1995) Asia-Pacific Tax Bulletin 314-320

“The Need for Further Reform of Australia's International Taxation Rules in View of the Spotless Services Case", (1996) Bulletin for International Fiscal Documentation 164-176

"Tax Reform Issues in the 1990s: A Case Study of Lebanon and its Prospects for Long-Term Prosperity” (1998) Arab Law Quarterly 107-153

"Spotless: A Lesson in Form and Substance but not in Substance over Form” (1998) Revenue Law Journal 175-198

“Tackling Tax Treaty Tensions: time to think about an International Tax Court” (1998) Bulletin for International Fiscal Documentation 344-357

“Letter-to-Editor”, Financial Times (3 April, 1998) (propounding an option for dealing with the emerging markets financial crisis)

Book review: Changing Tax Law in East and Southeast Asia Towards the 21st Century, (1999) Asia Pacific Law Review 259-264; and International Institute for Asian Studies – Newsletter Issue 18

Book review: Tax Law Tax Law Design and Drafting (Vol. 2): Comparing Income Tax laws of the World, (2000) Berkeley Journal of International Law (Vol. 8:1) 201-208

Challenging transfer pricing determination in light of Daihatsu (2003) 7/2 The Tax Specialist 69-82 (also published in Tax Notes International Vol 31, No. 2 at pp 159-175)

Plaintiff’s Rights of Recovery not Extinguished (2004) 42/8 Law Society Journal 56-59

Letter-to-the-Editor (2004) 78 Australian Law Journal 631 (commenting on McHugh J’s dissent in Cole v South Tweed Rugby Club (2004) 217 CLR 469)

Recent Articles

"Judicial Review of the Accountant's Concession: A case for improving tax administration and accountability" (2011) 21 Revenue Law Journal pp 107-145

"Prosecuting Liquidators in Non-Appointing Courts: A case for overturning outdated law" (2011) 37(2) Monash University Law Review pp 97-131

Conference Papers

International Tax Policy: Australasian Tax Teachers Conference, (Christchurch, New Zealand, 1993)

Transfer Pricing Compliance Costs for SMEs: 53rd Congress of the International Institute of Public Finance, (Kyoto, Japan, 1997)

Home and Host Country Taxation: 7th Asian Development Bank Tax Conference, (Singapore, 1997)

8th International Workshop on Commercial Law (3 August 2011), Johannesburg, South Africa.

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