Self Employed Australia

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“Everyone needs an Advocate”

Reforming the ATO

We give evidence on Tax Fairness solution to UK Parliamentary committee/group

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UK-parliamentFor over a decade we’ve been campaigning for fairness and for rule of law principles to be applied when the ATO assesses and administers alleged tax debts, particularly those of self-employed, small business people.

We have found a template ‘solution’ based on how USA law requires tax administration fairness from the IRS. Here’s a video explanation and a one-page summary.

It transpires that the UK also has very similar problems with its tax administrator (HMRC) abusing self-employed people. We have a long-standing campaigning partnership with Contractor Calculator in the UK who, like us, campaigns for tax administration fairness. The UK problem is so severe that an all-party parliamentary group/committee has been formed to seek a solution to HMRC abuse. Some 250 UK MPs are in the group/committee.

Last month (on 21 February) we gave a joint presentation to the Taxpayer Fairness Group’s senior parliamentary members. We offered them a vision of a solution based on the USA model which we also recommend for Australia. Three of us gave presentations followed by Q&A (YouTube links below).

Ken-Phillips     Dave-Chaplin     Jason-Falinski

Jason made some strong points:

“At the core of this is whether governments exist to serve people or citizens exist to serve government … we have provided tax agencies in the Western world with extraordinary powers that are in breach of some pretty fundamental legal rights…”

We provided the UK parliamentary group with:

Almost exclusively, tax debates are about how much money is or should be taken out of which pockets of the people. But the way tax laws are administered cuts to the heart of the power of government over the people. And by ‘government’ we mean the faceless tax bureaucrats who administer the inevitable maze of tax laws.

Tax law administration must be subject to transparency, accountability and checks and balances so that the rule of (tax) law applies in a practical way. That is not the case in Australia nor, it seems, in the UK.

Our campaign is to secure that rule of law. The US model offers a practical template for reform.

 

ATO Mongrel Bunch of Bastards Continues—Morrison Needs to Act

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Today we release details of continuing abuse of small business by the ATO.

You may remember that in 2018 we were heavily involved in the production of the ABC 4 Corners program Mongrel Bunch of Bastards. The program exposed the gross abuse of small business people by the ATO. Since then we have campaigned hard for reform to the ATO’s audit and enforcement division, which is where the problems exist.

This time, in our view, the abuse looks like a massive ATO cover-up of the largest tax scandal in Australia’s history. Surely not, we ask?

As background, between around 2012 and 2015, international criminals defrauded an estimated $2.45 billion from the ATO through a GST scam involving gold trading. Adding to the scandal is that the scam was well known to the ATO from around 2003. The way to stop the scamming was well known, but the ATO did nothing until it was too late.

In our view and on the evidence, after allowing the scam to occur and after the criminals have disappeared, the ATO is seeking to cover up its huge incompetence or worse. It is doing this by attacking innocent small business people to deflect attention from its own serious shortcomings. This is our assessment. However, an official government report into the ATO’s treatment of small business on this issue is scathing of the ATO.

The report from the ATO watchdog, The Inspector General of Taxation Ombudsman (IGTO), looks at the case of small business owners Lynn and Jerry Reid who run a small gold refinery on the Gold Coast. The ATO has withheld $1.3 million of GST refunds from Lynn and Jerry that is due to them. But get this. Even though Lynn and Jerry don’t owe the ATO any money, the ATO has ‘invented’ a technical ‘tax penalty’ and now say that Lynn and Jerry owe the ATO $173,107. We say it’s a total fabrication. The ATO could pull this sort of stunt on anyone.

The IGTO report says that the ATO has no evidence to justify its raiding of Lynn and Jerry’s bank accounts to collect the $173,107. The ATO has not accused Lynn and Jerry of criminal activity or of doing anything wrong. The IGTO says that the ATO must:
  • Issue an apology to Lynn and Jerry.
  • Compensate Lynn and Jerry for harm done to them.

It’s an appalling story of abuse which we’ve detailed in our summary/commentary. Here is the IGTO 77-page report.

Lynn and Jerry are just two more victims of an abusive, dysfunctional ATO audit and enforcement division. This sort of ATO abuse must be made to stop. We call on the Morrison government to recognise that it has a serious problem with the ATO and to urgently undertake ATO reform.

We have studied the USA reforms to its tax authority—the IRS—and submitted a report to parliament. The US model provides a valuable, proven template for Australia.

Frankly, enough is enough. Reform action is needed now. Continuing abuse of small business people like Lynn and Jerry must stop. The Morrison government cannot sit back and continue to watch this destruction of small businesses.

BIG change must happen to ATO says government report

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Wednesday, March 03, 2021

The Federal government’s small business agency, the Small Business Ombudsman, has called for major changes to the way the Australian Taxation Office operates. The Ombudsman, Kate Carnell, says “… the time is right for Government to deliver a [tax administration] system that suits the small business sector…”

We totally agree. The ATO’s approach to small business is bullying, unfair and oppressive. We’ve been highlighting this since around 2012 and have been calling for major change. See our 20-minute video.

The Ombudsman has recommended 25 specific changes to the operations of the ATO. (See pages 6-8 of her report released today.) The recommendations are practical and sensible. The one we highlight as top of our list is Recommendation 21. This says:

ATO to be prohibited from charging penalties and interest, issuing garnishee notices or instigating other recovery action on tax debt … until all avenues of appeal taken by the small business taxpayer are exhausted, with general interest charges (GIC) to be applied only from that time.

This is sensible, totally fair and hugely important. And it comes within the context of a big increase in small business tax debt to $21 billion during Covid.

But it’s essential to be clear about what this tax debt actually is. It’s made up of (a) tax actually owed, (b) interest and (c) penalties the ATO adds on. The ATO has continually refused to give the split of these items in reply to parliamentary questions. But here’s just one case as an example.

A small business that we’ve been working with for many years has a tax dispute over

$83,576 the ATO says is owed (over 2 years).

The ATO has added

$41,788 in penalties and
$99,600 in interest (approx.) to today’s date.

That is, the ATO says around $225,000 is owed. The dispute and appeals process has been ongoing for seven years.

However, if the Ombudsman’s recommendation were applied, the actual debt would be $83,576.

This highlights how important Recommendation 21 is. It is a reform which would produce an honest reflection of the truth of the actual tax debt.

In other words, the ATO’s approach to tax debt is, in our view and experience, shonky and misleading. In the case outlined above the real tax debt is only 34 per cent of the ATO’s claim. On this basis the ATO’s headline-grabbing ‘$21 billion’ of small business debt would really only be $7 billion. The point is that we need facts and truth, not misleading media-grabbing headlines.

The Ombudsman’s Recommendation 21 would push toward the truth and make ATO debt management fair and much more efficient. Did we say that we support the Ombudsman in her efforts? Well clearly we do. We’ll produce a more detailed commentary soon.

ATO abusing its powers – manipulating the law to abuse people

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Our campaign to reform the ATO continues. Good grief it’s an exhausting process! But the ATO keeps demonstrating why the reform is needed because the ATO keeps behaving badly.

Today we’re highlighting another case of ATO bad behaviour.

Many small businesses are structured as trusts. Most are family trusts. The ‘beneficiaries’ of such trusts are typically family members. A trust can distribute profits to the beneficiaries who then pay the tax.

In the ‘Carter case’ (see full details here) the ATO ‘assessed’ that the trust had made a profit. And here’s what then happened:

  • The ATO declared that Natalie Carter, a mother with two school-age children, had received profit from the trust as a beneficiary.
  • The problem was that no profit had been made. The ATO assessment was wrong. The ATO didn’t deduct expenses (interest etc) from the trust revenue. The trust had not sent any profit to Natalie because there was no profit.
  • But the ATO still said there was profit and forced Natalie to pay tax, even though she had no income.
  • Natalie then did what has been accepted as law for thirty years. She signed papers legally rejecting the (theoretical) profit. Sounds sensible. But no! The ATO refused to refund the tax already paid.
  • Natalie appealed to the Federal court where all three judges agreed with Natalie. She owed no tax! Natalie won. The  ATO lost.
  • But the ATO is now appealing to the High Court, arguing that even if someone has not received a profit they must still pay tax. Crazy!!!! It’s just stupid.

Here’s how this weird obsession by the ATO to win—even when they are wrong—would play out. Say this 30-year law were chucked out.

  • Take a divorce where the husband is a real b…. scam man. He has a business with a trust. He has the trust make a profit but then disappears overseas with all the money and his new mistress. He also makes a theoretical profit distribution to his ex-wife. The ATO says the ex-wife must pay the tax. But if the wife cannot legally declare that she doesn’t want the theoretical profit she is screwed. The ATO force her into poverty. Nice one ATO!

Sensible laws are there to protect people from scammers. What the ATO is seeking to do in the Carter case will enable the ATO to facilitate corrupt behaviour.

The Carter case is just another example of why the ATO must be reformed.

Let’s be clear. The reform of the ATO is needed in the audit and enforcement division where abuse of small business people is pretty much routine. That division is out of control.

A gold-lined ATO stuff-up blows up in the ATO’s face

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Here’s an ATO story that might interest you.

On Friday last, 6 November, the Australian Taxation Office had a serious legal bomb blow up in its face. It’s so serious that the full bench of the Federal Court has put a ten-day embargo on the publication of the judgment that went against the ATO. We can only guess why. However, the case, the facts and the implications are known.

In essence, about four years ago the ATO destroyed the Australian private-sector gold-refining industry. It did this after international criminals ripped off up to a billion dollars in GST through trading gold. The gold refiners were unwitting conduits in the massive scam. Instead of chasing the criminals, the ATO attacked the refiners, most of whom were small businesses, effectively bankrupting many in the sector.

The scandal for the ATO strikes at the core of its competency or rather its incompetency. The criminal scam was possible because of a known loophole in the GST legislation. In the early 2000s, international criminals had pulled off the same scam in the UK and other jurisdictions. Those countries amended their VAT (GST) laws around 2004 thereby closing the loophole.

The ATO knew about the VAT (GST) scam and how to stop it. If it didn’t, it was stupid. It did nothing. In 2012 the criminals moved into Australia. ISIS operatives are believed to have been involved. The scam was slick in its simplicity.

The criminals sold impure gold to the Australian refiners. The refiners processed the gold to a purity suitable for bullion. The refiners paid GST on their purchases as is normal. The criminals didn’t forward the GST to the ATO and disappeared. This went on for four years until April 2017 when the ATO finally moved to have the legal loophole closed.

It’s a reasonable assumption that some refiners acted in collusion with the criminals. But it is clear from internal ATO documents that it pursued a deliberate strategy not to target the GST thieves but instead to pursue what it called its “refiner retention strategy” to hamstring the refining industry.

The ATO took a blanket ‘kill the industry’ approach. It can only be speculated as to the ATO’s motivation. Perhaps the ATO was seeking to cover up its gross incompetence by not stopping the scam before it started and then allowing it to continue for four years before acting.

The ATO instigated standover tactics against the refiners and refused to refund GST credits. This quickly sent refiners to the wall. The ATO followed up by issuing fines and penalties. Significantly the ATO did not move against the only government-owned refiner, the Perth Mint. Why?

But a feisty liquidator stood up to the ATO. The ATO issued a debt against a company for around $200 million. The case went to the Administrative Appeals Tribunal with the ATO winning. The liquidator appealed to the Full Bench of the Federal Court. That’s the decision announced on Friday. The ATO lost 3-0 after spending (on some estimates) $40 million in legal fees.

We don’t yet know the details of the Court’s ruling, but we do know the argument mounted by the ATO.

The ATO admitted in evidence that the targeted company was not involved in the criminal activity. But to justify its stance the ATO ran what to this layperson is an eye-wateringly technical and bizarre argument.

The ATO asserted that the refiners were not ‘refining’ the gold they had purchased from the criminals. The ATO used an ‘expert’ to run this argument. Then it conducted an ‘independent’ review. The ATO’s expert headed the review which found that his assessment was correct. Pardon me but, surprise, surprise!

The ATO has now lost in the Federal Court. The immediate implications seem to be that the Federal government now arguably owes the states around $1 billion in GST. Further, that the refiners are owed the (withheld) GST refunds which presumably run into the hundreds of millions of dollars. And refiners attacked by the ATO should be entitled to large scale compensation.

This case goes to the core of the ATO’s approach to auditing and enforcement. In this gold-refining case the ATO ‘stuffed up’ on a massive scale. It failed to move against a known criminal scam with years of notice. It failed to close the scam down during its four years of operation.

In response to its huge failure the ATO sought scapegoats. It targeted innocent refiners who were unwitting tools in the criminal scam. It used its unrestrained powers to bludgeon businesses, regardless of the facts. We see this constantly, particularly with small businesses who either collapse or give in to the ATO because they don’t have the resources to fight back.

This time, after some six years, a liquidator with the resources has proven the ATO wrong.

Lessons must be heeded. The ATO enforcement division is out of control. It’s a wrecking ball in the economy whenever it targets individual businesses or sectors. It wrecked the research and development policies of the government through the same sort of incompetence and vindictiveness demonstrated in the gold-refining case.

The ATO has proven that it cannot reform itself. Reform must be imposed by legislation. A template for such reforms is available based on successful reforms in the USA to its tax authority. Coincidentally I discussed this in an article last week.

Australia cannot afford an ATO that continues to operate as it currently does.

“Reform the ATO”, says Senator. An important speech!

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There has been a major development in the last days of Federal Parliament for this year. For the first time a parliamentarian has made a clear call for reform of the Australian Taxation Office.

Liberal elder statesman Senator Eric Abetz is a former senior minister and government leader in the Senate. Last Wednesday (4 December) he delivered a punchy speech in which he demonstrated why the ATO needs to be reformed. He also outlined a model for how that should be done.

The Senator’s five-minute speech can be viewed here. It’s short but significant!

Senator Abetz referred to

“…the heavy-handed, non-transparent way in which the ATO is treating too many self-employed Australians.”

He added that reform is needed that will “…hold the ATO to account”. And he pointed to the USA’s tax administration laws as a model where, for example:

“… a tax debt … can only be collected once appeals have been exhausted, rather than as soon as it is claimed …” (as happens in Australia)

Senator Abetz’s speech is important because this is the first time in the Federal Parliament that someone has clearly staked out the need for reform of the ATO. It’s a sign that our parliamentarians are becoming sick of constantly hearing stories of the ATO’s abuse of taxpayers and that they want to see the ATO fixed.

We will keep you informed of developments.

Explosive, gobsmacking statements by Tax Commissioner raise serious concerns about democracy, the rule of law and cover-up

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Perhaps we thought we’d seen just about every ‘trick’ by the ATO, but the statements by the Tax Commissioner to the Senate on Wednesday (23 October) go to an entirely new level. The ATO ‘battle bar’ has just been raised, big time!

What has motivated the Commissioner is the ‘Right to Know’ public campaign being conducted by a large coalition of Australian media interests against the government’s suppression of free speech. This week ‘Right to Know’ released its first television/on-line advert. The opening ‘punch’ in the advert asserts that the ATO can take money directly out of people’s accounts “but you’re not allowed to know…”

The Tax Commissioner denies that the ATO does this. He said to the Senate  “We use garnishees and other firm actions only after these attempts to engage the taxpayer have failed.”

We can advise Senators that this statement by the Commissioner is wrong and misleading.

We have firm, documented evidence of at least one occasion where the ATO emptied someone’s bank account without telling that person. The person did not even know that the ATO had raised a debt against them. The person did not receive notice from the ATO until ten days after the ATO cleaned out their bank account. This evidence has been supplied to a formal government investigation into the ATO.

The Tax Commissioner went further. He attacked the two public ATO whistleblowers. He divulged highly personal information which, in the case of Richard Boyle, is subject to criminal court proceedings.

The printed version of The Commissioner’s statement is here. An online video version is available here. You can access the key comments in the video by going to the following time-marks:

(duration time) 01:03:00 — Commissioner denies Right to Know allegation of ATO taking money without people knowing.
(duration time) 01:06:30 — Commissioner begins attacking Richard Boyle.
(duration time) 01:15:20 — Commissioner claims IGT report cleared the ATO. (Note: This is untrue.)
(duration time) 01:22:00 — Commissioner finishes opening statement.
(duration time) 01:25:30 — ALP Senator Katy Gallagher asks questions.
(duration time) 01:28:30 — A shocked Senate Committee suspends proceedings to privately consider what to do.
(duration time) 01:37:45 — The hearing restarts. Centre Alliance Senator Rex Patrick makes comments.
(duration time) 01:46:20 — Finishes.

Note the restrained but shocked reaction of the Senators.

There has been massive media coverage. Including The Australian (‘Tax Commissioner Chris Jordan flays media over ‘whistleblower’ coverage’), The Age/SMH (‘Tax Commissioner attacks ‘out of control’ press over whistleblower reporting’), The Mandarin (‘ATO responds to press freedom campaign’),  the ABC (‘Tax boss Chris Jordan hits back at ATO whistleblowers and media reporting’), the AFR (‘ATO boss Chris Jordan attacks whistleblowers’), the SMH/Age (‘”Absolute devastation”: The whistleblower who will “never work again” after helping tax watchdog’), the SMH (‘ATO appalling in its treatment of public servant, says Fair Work Australia’)  and the SMH/Age (‘ATO’s Chris Jordan seeks to shoot the messenger’).

Following the Senate hearing, Greens Senator Whish-Wilson has asked for the Tax Commissioner’s statements to be ‘expunged’ from the official Hansard. The media report states that “Senator Whish-Wilson requested this happen given information provided by Mr Jordan ‘went beyond what was public knowledge’, was subject to pending court proceedings, and the individuals named had no immediate right of reply”. But can what has been said so publicly be ‘undone’? Justice is at stake!

It would be for a court to decide, but has the Tax Commissioner just made a fair trial for Richard Boyle now impossible? Has the course of justice been perverted under parliamentary privilege?

The behaviour of the ATO reminds us repeatedly of the banks denying financial misbehavior, the churches denying sexual abuse by clergy, large firms denying underpayment of workers and more. In those instances the large organizations’ behaviour seems to fit a set pattern which involves:

  • Denying the evidence of their bad behavior.
  • Attacking the people who expose the bad behavior.
  • Claiming the organization is nonetheless good.

Every time the pressure builds until there is an explosion. When that happens:

  • The truth overwhelms the denials by the large organization.
  • All hell breaks loose.
  • The top people in the organization are forced to resign or are sacked.
  • The task of cleaning up the organization begins.
Because the ATO is an arm of government, ‘all hell breaking loose’ will not happen until the government considers that the ATO is doing damage to it politically. Events are inevitably heading in that direction. The question is: How long will it take for the Morrison government to reach that conclusion?

We need your help to defend democracy from an aggressive ATO bureaucracy—Richard Boyle GoFundMe

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This is a very special appeal for your help to defend against the ATO small business bully.

We’re asking you to contribute to the legal defence fund for Richard Boyle, the ATO whistleblower. We consider Richard a hero for democracy. He exposed the truth about ATO abuse at great personal risk to himself and his family. We must support Richard.

Richard is facing a staggering 161 years in jail under ATO prosecution. Mass murderers don’t face this. It demonstrates the vindictiveness of the ATO.

Richard provided key evidence in the Four Corners exposé ‘Mongrel Bunch of Bastards’, which aired last year. The program triggered a tsunami of media, parliamentary and official reports that continued throughout 2018 and into this year—all confirming the ATO’s bullying behaviour.

The facts of Richard’s situation are as follows:

  • He worked for the ATO for some 13 years specialising in the debt-collection area. That’s the area where the ATO can take money from your bank account without your permission or knowledge. The ATO can do this if they think you owe money. No proof needed!
  • Richard witnessed the ATO undertaking aggressive and dubious processes to grab money.
  • He lodged an official, internal ATO report on this. He was told to shut up and ignore the ATO’s bad behaviour.
  • Richard then lodged an official report to the ATO investigator, the Inspector-General of Taxation and told his story on Four Corners.
  • The ATO raided his house and sacked him.
  • Now the ATO is prosecuting Richard.
  • The official Inspector-General’s Report confirmed Richard’s allegations of ATO misbehaviour as did several other official reports.

The ATO has a river of money to fund its prosecution of Richard. Richard is unemployed.

There are times when we must stand together. Otherwise democracy and the rule of law mean nothing. Richard is a hero. We need to stand with heroes. Richard deserves to have the funds to conduct a proper legal defence. That’s the least that we can do. Please give.

It doesn’t matter how small your contribution. But please give what you can afford.

You can donate to the GoFundMe campaign here.

We ask MPs: ‘Stop this ATO bully boy tax Bill’

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We rushed into action late Saturday night when we discovered that a really scary tax Bill was listed for a vote in Parliament this week.

The new law is supposed to stop illegal phoenixing. (That’s when someone sends their business bankrupt then ‘rebirths’ it under another name. They leave victims with huge debts.) But this new law would instead empower the ATO to:

  • Do a forward estimate on how much a business owed in GST.
  • Demand payment whether the ATO’s estimate was correct or not.
  • Deny someone a tax refund (say on overpaid income tax).
  • Make company directors personally liable for the estimated GST.

This has nothing to do with stopping phoenixing. It is instead a further cunning power grab by the ATO. This would give the ATO new powers to ramp up its small business bullying campaign.

On Sunday we wrote to the government and all MPs and Senators asking them to stop this bad law. Robert Gottliebsen wrote in The Australian condemning the law. We spent Monday and Tuesday in Parliament talking with MPs and Senators asking for the law to be pulled. We’ll let you know what happens.

But, while this was occurring, the ATO created news coverage by saying that it is introducing new ‘procedural safeguards’ to prevent ATO bullying of small business people. The article stated that the ATO is to “…overhaul its internal culture to avoid a repeat of the embarrassing ‘garnishee’ scandal that damaged its reputation among small-business taxpayers.”

Give us a break!!! The ATO puts out PR spin saying that it is going to stop its bullying culture and behaviour. Yet at the same time it is seeking to sneak through Parliament new laws that will increase its bullying powers. The ATO is engaging in an outrageous community, media and parliamentary con. It’s got to stop.

Quite recently we praised the ATO for a new, independent appeals process. We’ll continue to praise when we see good things from the ATO. But we’re not going to fall for the ATO’s two-faced con.

If the ATO is serious about addressing its bullying—particularly over garnishee issues—then prove it! It should drop its persecution and prosecution of ATO whistleblower Richard Boyle. He exposed the ATO’s garnishee bullying behaviour, the very behaviour the ATO says it now wants to stop. For exposing this the ATO is now trying to send Richard to jail for 161 years. The ATO’s credibility is in tatters. Its behaviour is like that of the worst bank behaviour.

US Congress and Trump agree. Discipline the IRS to prevent taxpayer abuse. Message for Australia

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1 July 2019 proved an historic day for US taxpayers when President Trump signed into law the Taxpayers First Act.

The Act is intended to bring discipline to the US tax agency (IRS) after years of strong evidence of both its administrative incompetence and systemic abuse of taxpayers, particularly small business people.

The Bill passed Congress with support from all political parties.

There’s a massive lesson here for Australia. If we’re to be internationally competitive, we must bring justice and the rule of law to the way the Australian Taxation Office administers tax.

In Australia, particularly over the last 18 months, the evidence of ATO abuse of small business people has mounted and is overwhelming. See, particularly, the Four Corners program, ‘Mongrel Bunch of Bastards’.

The US Taxpayers First Act has specific provisions to protect small business owners from IRS seizures of their bank accounts. There is major evidence that the IRS has been wildly abusing its powers to seize bank accounts in cases where there was no evidence of small business taxpayers avoiding tax. The stories here strongly resemble those we see with the ATO garnisheeing bank accounts in Australia. Read the Small Business Ombudsman’s report on the ATO’s garnishee abuse.

Of the twelve-or-so measures in the US Taxpayers First Act, the following six are highly relevant to the sort of things we should be doing in Australia to reform the ATO.

  1. Greater Access to Independent Review: Guarantees taxpayer access to an independent appeal on an audit decision. Before an appeal the IRS must hand over to the taxpayer the taxpayer’s case file.
  2. Limited Seizure of Property: Property seizure limited to illegal cash transactions or concealing criminal activity. Post seizure and hearing requirements to protect taxpayers. (***Highly relevant to the ATO garnishee issue)
  3. Listening to the Taxpayer Advocate. The USA has an independent Taxpayer Advocate (NTA), a bit like the Australian Inspector-General of Taxation (IGT). The US law would grant the NTA significant new powers to give the IRS enforceable directives on taxpayer cases.
  4. Improved customer service: IRS required to adopt best practices of private sector customer-service providers.
  5. Easier Settlement Procedures: No fees by IRS if a settlement deal is done with the taxpayer.
  6. Earlier Notice of third-party questioning: The IRS must notify a taxpayer before it makes enquires of third parties about your tax (for example, a customer).
In 2018 we put together a position and discussion paper for a package of reforms of the ATO. Nothing in our reform package involves reducing the ATO’s powers to collect tax. It’s about ensuring checks and balances and the proper application of the rule of law to the ATO’s powers and behaviour. Since the federal election outcome we have started our advocacy campaign to make progress with ATO reform. We will release more on this over the coming weeks/months.