Detailed Answer

    A well-structured tax research memo follows the IRAC pattern — Issue, Rule, Analysis, Conclusion — adapted for Australian practice with explicit legislation and ATO citations.

    The reviewer (a TPB-registered tax agent or qualified CA/CPA) signs off before the advice goes to the client.

    Cassandra can produce a first draft of the memo grounded in primary sources — but the professional remains responsible for review and the final advice.

    The Problems Professionals Face

    Step 1

    Where to start

    → Capture client facts in writing

    Step 2

    What comes after step 1

    → Frame the precise tax issue

    Step 3

    What comes after step 2

    → Identify applicable ITAA sections and ATO rulings

    Step 4

    What comes after step 3

    → Summarise relevant case law

    Step 5

    What comes after step 4

    → Apply the law to the facts

    Step 6

    What comes after step 5

    → State the conclusion and any qualifications

    Step 7

    What comes after step 6

    → Reviewer sign-off

    Key Capabilities

    Primary Sources

    ITAA 1997/1936, GST Act 1999, ATO rulings, Federal Court decisions

    Citation-Aware

    Use source references to check the draft against the applicable authority

    Professional Review

    Outputs require independent review by an appropriately qualified practitioner

    Why generic AI is risky for 'how to prepare a tax research memo'

    • Generic AI tools hallucinate Australian legislative section numbers and ATO ruling identifiers
    • AI can misidentify the applicable version of a provision
    • Check the status and binding effect of any ATO guidance cited
    • Using unverifiable AI in professional tax work risks the TPB Code of Professional Conduct

    How Cassandra handles this

    • Australian tax and legal research workflows
    • Check any cited ITAA section, ATO ruling or case against the official text
    • Independent professional review is required before relying on an output
    • Check the relevant income year, amendments and status directly with the issuing authority

    Editorial Standards

    ABN 70 659 258 367
    Australian-registered company
    Publisher
    Cassandra Research — see /about
    Review Required
    An appropriately qualified practitioner must verify the facts, sources and conclusions
    Primary Sources
    ITAA 1997/1936, GST Act 1999, FBTAA, Corporations Act 2001
    Last Updated
    2026-06-01
    Corrections Policy
    See /corrections

    Frequently Asked Questions

    Structure the memo with: client facts, issue, applicable legislation, ATO guidance, case law, analysis, conclusion, and reviewer sign-off. Cite every primary source.

    Cassandra Research publishes this general overview. This page does not certify individual authorship or a registered practitioner's review; independently check the sources and consult a qualified practitioner before relying on it.

    Check the applicable income year, legislation, ruling status and subsequent decisions directly with the relevant authority. A page date does not establish that the legal position is current. See /corrections to report an issue.

    This page is general information, not personal tax advice. Always confirm with a TPB-registered tax agent or admitted lawyer before relying on it for client work.

    Every primary source referenced — ITAA sections, ATO ruling numbers, and case names — can be verified on the ATO Legal Database, Federal Register of Legislation, or AustLII.

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    Author: Imran Hussain
    Author credentials and editorial bio
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