TaxVibe

Episode 16 — 2022 in our sights

February 10, 2022 The Tax Institute Season 1 Episode 16
TaxVibe
Episode 16 — 2022 in our sights
Show Notes Transcript

In this episode of TaxVibe, Robyn chats with Julie Abdalla, FTI, Tax Counsel at The Tax Institute about what’s in store on the tax front for the year ahead, including:

- PCG 2021/4
- Section 100A
- Division 7A
- Individual residency
- Corporate/multinationals (Sharing economy, LPP protocol & more)

Host: Robyn Jacobson, CTA 

Guests: Julie Abdalla, FTI 

 Robyn Jacobson:
 Hello and welcome to TaxVibe, a podcast by The Tax Institute. I'm Robyn Jacobson, a senior advocate at The Tax Institute and your host of today's podcast. We love the vibe of tax, and here at The Tax Institute we do tax differently. I'll be chatting with some of the tax profession's great thought leaders that will share valuable and practical insights you may not hear every day. We hope you enjoy this episode of TaxVibe. I'm joined by Julie Abdalla, who is the tax counsel at The Tax Institute. Julie's an experienced tax lawyer and emerging leader. She has practiced in the corporate tax teams of big four and top tier law firms in Sydney and Melbourne. Julie also gained experience across the spectrum of UK taxes while working at an international law firm in London.
 
 Robyn Jacobson:
 Julie has a strong passion for tax policy and reform, and the depth of knowledge to advocate for members. She has been recognized among her peers and throughout the profession for her leadership and excellence in tax. Julie holds a Bachelor of Arts and a Juris Doctor from the University of Sydney and a Master of Laws from the university of Melbourne, part of which was completed at the University of Oxford. Julie, welcome to TaxVibe for the very first time and, of course, our first episode for 2022.
 
 Julie Abdalla:
 Hi, Robyn. Thank you for having me. It's a pleasure to be here.
 
 Robyn Jacobson:
 I wish we could still do this in person at some stage, but for the time being we will still do this remotely, you in Sydney and me in Melbourne.
 
 Julie Abdalla:
 I know. It'd be nice to be in the same room, but I suppose that's one of the beauties of technology, that we can actually do this from totally different states.
 
 Robyn Jacobson:
 Absolutely. Look, we've already got ourselves one month into the new year. Can't believe it's February already. In terms of the holiday break, how did you chill out? Because, gosh, it was a big year last year. In fact, two big years, but how did you spend time to just recharge and break away from this tax law?
 
 Julie Abdalla:
 It was a big year, and you're right, it has been a big couple of years. My break was actually pretty short, but I became a proud auntie for the second time to another little niece so I had a lot of family time with them. I was actually in London when my first niece was born, so it was nice to actually be here this time and not miss out on the early stages where they're changing so much. That's been really fun. Otherwise, I had a pretty quiet break. I spent a lot of time in my garden. I've got this wild, lush garden and the complete introvert in me is speaking now but I really love spending time out there. Got this fish pond and I've managed to keep my fish alive, so very happy with that. What about you? Your break was probably a bit more adventurous than mine.
 
 Robyn Jacobson:
 Well, having been locked out of Melbourne for what feels like all of two years, and a few of our members may recall that beginning of 2020 I broke my foot and so I was laid up with a moon boot and keeping my leg elevated. I really feel like lockdowns for me began back in January of 2020, but I was able to do some trips around regional Victoria. One of the things I love doing is getting out in the car and doing road trips and country trips and catching up with friends and family so, look, I feel like I've covered the north of the state up to Yarrawonga and down to Geelong and down the peninsula and through the alpine area of Victoria. It was lovely to get some fresh air, not read tax. It may surprise some people, but yes I can go a couple of weeks without tax. It was lovely to recharge and have some time out.
 
 Julie Abdalla:
 When I lived in Melbourne, I used to love doing those regional trips out to different parts of Victoria. It's so beautiful out there. I mean, it's quite different from regional New South Wales but that's also really beautiful. I just love being in the country so I'm happy either way.
 
 Robyn Jacobson:
 And it's quite a compact state so with a few hours' drive you can cover a fair bit of it.
 
 Julie Abdalla:
 Easy to do, yeah.
 
 Robyn Jacobson:
 As we get back into the working year, how do we best pace ourselves? Now, that's you and I and our broader team and, of course, the profession more broadly again. We talk about New Year's resolutions and how quickly they are broken [inaudible 00:04:15] this way of approaching this when we're talking about getting back into the working year and how do you manage it?
 
 Julie Abdalla:
 Well, that is the million dollar question isn't it. I think, look, different things work for different people. I think, though, the past couple of years have been relentless and draining, especially in and out of lockdown and having to adapt to different working situations. But for me, I don't actually make any New Year's resolutions. I find that's a very good way to break them very quickly. I do like to set goals and there are things that I want to achieve throughout the year, but try not to put too much pressure on the beginning of the year by calling them resolutions. But it's a bit of balance, and balance isn't even a 50/50 thing. Balance is just what works for you on that day, during that week. It's exercise, it's managing work, it's spending time with my family and my friends in my garden. What about you?
 
 Robyn Jacobson:
 Look, I think it is time out. When you're looking at these beautiful long evenings we've got at the moment... I know WA doesn't have daylight savings nor Queensland, but for those states that do we have got these long evenings, and particularly in Melbourne and then more so down in Tasmania. Our highlights are so much longer than the northern states.
 
 Julie Abdalla:
 So beautiful.
 
 Robyn Jacobson:
 I have been making a point of getting out every evening and having a walk after work, and that's something I would love to maintain right through winter but that's one of those things that you strive to do and may not actually [crosstalk 00:05:41].
 
 Julie Abdalla:
 I always do it in the morning. I go out for a morning walk so I get it over and done with for the day, but you're right. It's so important to just take a moment to reset and refresh.
 
 Robyn Jacobson:
 So with a better year ahead, let's just flag some key dates coming up. Federal budget. Now, I've always described this as the most exciting date on the accountant's calendar. We're talking typically that second Tuesday in May, and I've already said cancel your social plans and if you're going to spend the evening with anyone else, it's got to be other accountants or lawyers where you order your pizza and have a beer or two and just enjoy the evening. But this year with the federal election having to be held at least in the Senate now, it's unlikely we're going to see two elections, one for the lower house last September. We are talking about, of course, a federal election by the 21st of May. That's brought forward the budget to the 29th of March, which is only a couple of months away. We will keep a very close eye on what is going on with that, but can you make a brief comment about what we've been doing lately? Because pre-budget submissions are an important part of gearing up for the federal budget each year.
 
 Julie Abdalla:
 Yeah, that's right. We've just lodged our pre-budget submission and it's something we do pretty much every year, and it's one way that we advocate for what our members and what the community wants and needs from our government in relation to tax and to the system. They're things that we put in there that we want to see in the upcoming budget and, I guess, it's a wait and see on budget night. I've been very privileged to actually attend the budget lock-up, which is where we have a first glimpse of the budget papers and the budget measures before the Treasury gives his speech on budget night. Hopefully we'll have that opportunity again this year. Of course, we'll be providing resources for our members to explain the impact of the budget measures.
 
 Robyn Jacobson:
 We're also going to have another disrupted parliamentary year [crosstalk 00:07:33]. In an ordinary parliamentary year, and I'm talking ordinary outside COVID and outside elections and anything else that might be a big disrupter.
 
 Julie Abdalla:
 I don't really remember those times.
 
 Robyn Jacobson:
 Feels like a few years now. We typically have around 19 or 20 sitting weeks a year, which doesn't sound very many but they need to spend time back in their electorates throughout the year. But with the election having to be held by May, and then of course we've got the caretaker period before that and the election campaigning, I've counted up we're unlikely to see much more than six sitting days before August this year, which might sound quite extraordinary but we've got a few sitting days in February, we've got the three days for the budget then we both are going to go into caretaker mode, the election will be called.
 
 Robyn Jacobson:
 I'll be very surprised if there are any sitting days at the end of June. It depends how long they're going to take to count the votes, but I think with COVID we're going to have a much higher proportion of postal votes than we might have seen in years gone by. That always takes longer to count those up and get them in, and then we've got the winter resets so it really could be August, September before we get any meaningful debate before the parliament. What does this mean when we've got such disruption to the legislative program? The business world has to keep on operating.
 
 Julie Abdalla:
 Well, that's right. The world keeps spinning, doesn't it? I mean, businesses going on, people are living their lives and we do need a degree of certainty from our taxes, and that's the problem. If we don't have enough time where parliament's sitting, we don't get legislation through, but we need to have some of these new measures coming through, we need debate and people need certainty. We need some degree of certainty from our tax system, and what we've seen in the changing landscape where things are moving pretty quickly all the time is that our system's just not coping.
 
 Robyn Jacobson:
 Our members recently will have received a copy of our State of Tax Policy Report which sets out the status of all the tax and superannuation measures that we think are key to our members. It'll be interesting to rerun that report roughly midyear because, of course, we will either have a returning coalition government or a new Labor government. Now, if it's returning coalition you'd expect any lapsed bills before the parliament to simply be reproduced, but they may take it as an opportunity to tweak some of their policies. If it's an incoming Labor government, then we would expect some changes in tax policy but that's all to be revealed. It's going to be in one sense a very disruptive year, but it's also a year of opportunity.
 
 Julie Abdalla:
 Absolutely. Absolutely. We have to keep hopeful.
 
 Robyn Jacobson:
 What are the key things on our radar at the moment? Now, we've got some things noted down here and we're going to across the SME sector as well as the large corporates, but what would you like to kick off with in terms of what we're keeping an eye on over the months ahead?
 
 Julie Abdalla:
 Okay. What about the professional firm's PCG 2021/4? The final version was issued in December last year, and so I think the dust is really still settling on this one. But PCG sets out the ATO's compliance approach to the allocation of profits or income from professional firms to in the assessable income of the practitioners that work in those firms. It does so through two gateways and a risk assessment framework of objective factors which are used to rate arrangements from low, medium or high risk. As we know, PCGs are essentially risk assessment tools. I think people are still really coming to terms with this PCG and what it means for their practices and how it affects business structures and operations. We've had a working group, a committee of our experienced practitioners involved in consultation with the ATO for quite some time now. I'm very conscious that PCG applies from mid this year, from 1st of July 2022, so we're working with our committee during this time to provide resources to educate our members on what they need to consider and what they need to do in light of the PCG.
 
 Robyn Jacobson:
 I think what's really important to note, and you made that comment about it being a risk assessment tool. Practical compliance guidelines, or PCGs, are not rulings. They might look like one and sort of have the flavor of one, but they don't explain the Commissioner's interpretation of the law or how the law applies to tax payers. What they do is set out the extent or the risk profile that they're likely to undertake a review or an audit of a taxpayer.
 
 Julie Abdalla:
 But it is how they allocate their compliance resources and what the Commissioner will consider as high risk or not, but it isn't a statement of the Commissioner's view of the law and we do need to be mindful of what they mean, how they operate, what reliance can we place on them.
 
 Robyn Jacobson:
 Another interesting thing we're keeping a close eye on, and this has been, I've got to say, dragging on for some years now, Section 100A. Anybody who has a trust and has distributions made to a beneficiary where, I'm going to describe it really simply, your cash goes one way and the distribution on paper goes somewhere else. It's a separation of profit and the economic benefit of that distribution. If [inaudible 00:12:33] agreement, you can end up with adverse tax on occasions for the trustee. Now, the ATO has been saying for some time that they would provide some guidance on this and they did delay it from late last year. They said it was ready at the time, but because of the pressure on the profession they said they would delay it until this year. Now, at the moment the ATO website is still indicating that this guidance is expected to be completed in February, but I think what is interesting, and we need to wait and see how this plays out, but there's been a recent Federal Court decision called Guardian.
 
 Robyn Jacobson:
 Now, I won't go through the detail of the case, but it is worth a read and we've also included a summary of this in our recent TaxVibe or [inaudible 00:13:11] The Tax Institute. But I think what's really relevant about this case, it is a single judge not three judges, but I would expect it to go on appeal to the full Federal Court. It deals with what is a reimbursement agreement and concludes that there wasn't one. It deals with whether there was an ordinary family or commercial dealing and the judge concluded, Justice Logan, that there in fact was this situation. In other words, they got the benefit of the exemption. And he went on to conclude that part 4A did not apply. To me, this case has everything and you just need to see whether this delays the ATO's guidance because it's hard to see how they could release a draft ruling and a PCG when potentially there's still an appeal still to play out. We'll keep a very close eye on this one.
 
 Julie Abdalla:
 Yeah. Look, I think it was a very sensible decision to hold off on releasing the guidance in light of what's going on and the pressure on practitioners. I think it would be difficult to see how finalized guidance would be issued at this stage. We do need to see what happens next.
 
 Robyn Jacobson:
 Now, dovetailing very closely with that, Division 7A. Can we ever have a conversation about SMEs and tax and not talk about Division 7A?
 
 Julie Abdalla:
 I don't think so. 
 
 Robyn Jacobson:
 I'm going to say we're heading into 11, 12 years now since the original review by the Board of Taxation was commissioned by the then Labor assistant treasurer way back in 2012. Now, we are still waiting for the proposed Treasury reforms. We have seen nothing formally from Treasury since 2018 when they released that discussion paper. We know the measures are deferred and they will commence on the first, 1 July following enactment of the enabling legislation. That's open ended. That could be anytime. Could be five, ten years from now, but in the mean time we do know that the ATO is going to be releasing a new package of Div 7A guidance, a new ruling, presumably a new PCG and possibly a new practice statement but that might all be bound up together in the PCG. We'll be very, very keenly following this. It's going to be highly relevant for many of our members and the broader profession, those that have, of course, trusts, private companies, et cetera so we'll keep a close eye on this one.
 
 Julie Abdalla:
 Absolutely. The guidance that the ATO's looking to release, that's quite distinct from the Treasury reforms, though, those reforms.
 
 Robyn Jacobson:
 Yes, it is. I think that's a really important point because people may get the two confused or even conflate them. Treasury putting forward a bill to parliament that amends the legislation is quite different from the ATO providing guidance on how to interpret the law, or indeed how they might approach risk reviews. So yes, this is distinct and, again, will be interesting to see what does it do, how does it rewrite the existing rulings. I'm referring to 2010/3 and PSOA 2010 form documents like that, which are then around for more than 10 years now. Maybe it's time to update them, but how does that sit in the context of the proposed reforms? It's really interesting to watch. So next issue, individual residency. We are still waiting and waiting and waiting.
 
 Julie Abdalla:
 We are waiting and waiting. As you know, last year there were those changes that were announced to the individual tax residency rules in the federal budget. The new framework is based on the recommendations made by the Board of Tax in its 2019 report. Essentially, it's proposed to consist of a primary bright-line test based on visible presence and then you've got a secondary test based on certain objective factors. I don't think we have time to get into the detail of all the challenges right now, but certainly with the Addy case and the ATO's recent decision impact statement there's a lot going on in the individual tax residency space and likely to be a significant overhaul of the rules. We haven't seen the draft legislation yet, but I think we'd anticipate there will be some consultation at that time.
 
 Robyn Jacobson:
 Is it too simplistic to boil it down to one core concern, and that is are we at risk of replacing one set of complex rules that require interpretation and possibly judicial guidance with another set of complex rules that require interpretation? Isn't that a significant risk here?
 
 Julie Abdalla:
 No, I think you're absolutely right. If you think about the litigation of these kind of matters over the past few years and when they changed the rules earlier, exactly as you say, replacing complex rules with more complex rules. But I don't know that that's the answer.
 
 Robyn Jacobson:
 The date was 1 July 2009, that's when they changed or narrowed particularly the exemption 23AG. Since that time, we've had a whole bundle of taxpayers trying to argue that they in fact are non-residents because that way, the incumbent would otherwise be assessable in Australia, could be exempt, and most of them have been unsuccessful. Onto the corporates and the multinationals. What do you see as, I guess, the top priorities or the key areas that we are keeping a very close eye on?
 
 Julie Abdalla:
 Well, sticking to the theme of residency, corporate tax residency is another to keep an eye on. In the 2021/22 federal budget, the government announced technology amendments to clarify the corporate residency test and those amendments would basically provide that a company that's incorporated offshore is treated as an Australian tax resident if it has a significant economic connection to Australia. Those changes have been really welcomed. Last year, a further announcement was made by the government that they would consult on extending the rules to trusts and CLPs, so corporate limited partnerships. Consultation hasn't taken place yet and it's been delayed a number of times, presumably due to other priorities, but we anticipate it'll commence in the coming months. That's one area to keep an eye on.
 
 Julie Abdalla:
 Pillar One and Pillar Two... Now, of course, we don't have time to get into the detail here, but at a very, very high level we've got Pillar One, which is about ensuring profits are allocated more appropriately, Pillar Two which is essentially implementing a global minimum corporate tax rate. There have been ongoing negotiations for quite some time, which are expected to progress throughout the year. I think it goes without saying that it's an ambitious timeframe for go live, if you will. It's really interesting to see the interaction between tax and accounting and the administrative aspects as well. I know Treasury and the ATO are working really closely together. It's also interesting to think about the policy designs going on, so that's a watch and see over the next 12 months, I think.
 
 Robyn Jacobson:
 What's happening with the sharing economy? Because we've seen a lot of noise and activity in relation to Airbnb and Uber and the like, but we're getting a new legislative framework that's going to allow more data sharing with the ATO.
 
 Julie Abdalla:
 Yes. Well, we think so, depending on how the parliamentary sittings go. This measure... You're right, it does have its roots in the efforts of the shadow economy taskforce recommendation. Last year, we actually appeared before the Senate Economics Legislation Committee inquiry into the bill and we've been keenly tracking its progress. The proposed start date for taxi travel and short term accommodation is 1 July of this year, and for pretty much every thing else that's captured is 1 July next year. The bill hasn't been passed though, so potentially in the upcoming parliamentary sitting this month but we don't know. We do understand the ATO will be consulting on administrative issues with the implementation of the regime, including the need for public advice and guidance and, of course, reporting requirements so watch this space.
 
 Robyn Jacobson:
 Few things to keep an eye on there. Legal professional privilege pressure cult. Try and say that quickly three times.
 
 Julie Abdalla:
 It's a tongue twister, but it's a very important fundamental concept, the LPP... Well, it's a fundamental right of all clients, and including taxpayers who seek legal advice. What the protocol attempts to do is document the ATO's view of what is best practice when making claims of LPP in response to formal information gathering notices from the ATO. There has been ongoing consultation with the ATO and certain groups, including The Tax Institute, and I know that the protocol has evolved over time due to that consultation, which is great to see. The ATO website at the moment is telling us that further consultation may take place, but expected completion is in March, so next month. So it remains to be seen whether it will change again since feedback was provided late last year or if that's it.
 
 Robyn Jacobson:
 One final measure in the corporate space, what is known as CCIV, corporate collective investment vehicles.
 
 Julie Abdalla:
 We do like a little bit of a tongue twister in the corporate space. Yeah, so the bill was introduced into the House of Reps in late November. It won't be debated until parliament resumes this year so, again, potentially in this February sitting, but it has been referred to the Senate Economics Legislation Committee and they will be reporting on it early this month. The main purpose of the bill is to create a new class of companies, so CCIVs, that any investors in which will be taxed on a flow through basis. At a very high level, it piggybacks off the AMIT rules, the existing attribution managed investment trust rules, but if the CCIV doesn't fall within those rules then its shareholders may be taxed under Div 6 or Div 6C.
 
 Robyn Jacobson:
 So, effectively, we're trying to attract foreign investment here.
 
 Julie Abdalla:
 That's right, we are trying to encourage foreign investment and it does have the benefit of relating back to the AMIT rules as well, which is something we're a bit more familiar with over the past few years since they've been around. It's actually been a long time coming. The new regime start date is 1 July this year, but the intention to create it was actually first announced in the 2016, 2017 federal budget. It'll be interesting to see how this progresses following standard inquiry as well.
 
 Robyn Jacobson:
 It will. When I hear you talk about AMIT and CCIV, it just makes me wonder if the government and the ATO have run out of three letter acronyms so they're having to move into four letter acronyms.
 
 Julie Abdalla:
 Well, let's hope we don't move to five any time soon.
 
 Robyn Jacobson:
 Creating new words by then. Here's another four letter one, IGTO. IGOT depending how you express it, but the Inspector-General of Taxation and Taxation Ombudsman is currently undertaking three reviews. Now, the office of the Inspector-General always has a web program available on their website setting out the work that they're doing, but what are these three particular investigations about?
 
 Julie Abdalla:
 This first one's about the ATO's administration and management of objections, second one's the exercise of the general powers of administration and the last one's about the exercise of the commissioner's remedial power. They're really interesting topics. We've been doing some work in the background on these issues and we've been engaging with the Inspector-General. It's always interesting for me to see how things are done in other jurisdictions as well to compare... Sometimes we can learn things from what other countries do, something that we should be doing or actually what not to do. And we'll be making three submissions in response to those reviews.
 
 Robyn Jacobson:
 Another issue we're looking at is the... Here we've got another four letter acronym, the ANAO, which is the Australian National Audit Office. Now, many of our listeners may not be aware that the role of the Australian National Audit Office is in fact to audit the government and government departments. They're currently conducting an audit of the ATO's engagement with tax agents. I have already mentioned on behalf of The Tax Institute with the ANAO we've had some initial meetings to talk about the scope of their audit and feedback that they're seeking. We have put a call out to our members saying, "If you've got any feedback on this, please let us know." They are calling for feedback right through til April, but we will continue to be meeting with them between now and then.
 
 Robyn Jacobson:
 This is a formal audit that gets sent in draft to the ATO, and then it will be actually formally tabled before the parliament, expected in August. It will interesting to see not just what the recommendations of the ANAO are, but what might come out of any reforms so changes could be made down the track to these processes. Another issue we're looking at, there is a current working group set up by the ATO called the Lodgment Program Review Working Group. Again, I am the Institute's representative in this working group and we are meeting with other professional bodies and some practitioners and the ATO and looking at the whole scope of everything that has to be lodged, the timing, all the different lodgment requirements.
 
 Robyn Jacobson:
 I think back 20 or 30 years ago where it had these lovely quiet periods in between lodgment season. Yes, [inaudible 00:26:10] April, May. Yes, you have a flurry of activity in June, your lodgments began July, business lodgments you typically have another rush before Christmas and maybe another one in May. With activity statements and TBARs and TPARs and, of course, tax returns and SG statements, there are so much now. It just seems to be a rolling cycle of lodgment obligations.
 
 Julie Abdalla:
 Practitioners certainly have their work cut out for them, and actually so does this working group.
 
 Robyn Jacobson:
 Absolutely. Once again, we're seeking feedback from members and we're keen to hear your thoughts and your experiences and what can be done to improve the current lodgment program. The last comment I wanted to make was in relation to the COVID business support. We had almost thought that we might be coming out the tail end of all these different programs and the vaccine level's so high, and yes Omicron is widespread and case numbers are up but its severity does not seem to be quite as bad as Delta and the previous variants. But that said, there is a hesitancy by consumers to go out in retail settings. We're certainly seeing an enormous staffing shortage where almost every business you have some sort of dealing with now, they're short staffed.
 
 Robyn Jacobson:
 The service is limited, it's taking longer to do everything and not just truck drivers, but shop assistants and hairdressers and all sorts of things. On the 30th of January, the New South Wales government announced another round of business support. Now, it would be a mistake to call this JobSaver 2 or JobSaver 2022. It is called the Small Business Support Program and what we know to date is that there will be a one off payment in February based on a decline in turnover of at least 40%. Now, the specific parameters and the features of the program we will be sharing in social media as well as in vlogs with our members but, of course, if you want the initial detail you can find that at the New South Wales Premier's media release webpage.
 
 Robyn Jacobson:
 Hopefully we don't have to continue to rely on government support to get through the remainder of the pandemic, but I think it would be unrealistic to think that we're not going to see further outbreaks. What we may well see is targeted or localized support rather than a universal program being rolled out like JobKeeper, or JobSaver in the case of New South Wales. More detail to come on this program. Obviously applications still need to open up and all the fine print needs to be worked through, but I'd like to think that we won't see too many more of these in the next year, but I hope I'm not proven wrong.
 
 Julie Abdalla:
 Fingers crossed. I mean, it is great to see the government still providing some level of support while I know there's a lot of effort to go back to normal, whatever normal is, and living with COVID, but we do have to acknowledge businesses are still struggling and people are still struggling through so it's great to see that support coming through.
 
 Robyn Jacobson:
 And not wanting to overlook members or practitioners or businesses outside New South Wales, do keep a close eye on your particular state or territory because, for example, I saw last week South Australian government has announced further support. I'd expect there might be something further from Victorian government, and with case numbers as broad as they are and businesses continue to be affected it is important that you do check your local state government websites to see what support is available to you or your client's businesses. Julie, as we wrap, big year ahead, lots of things in store, but there's that certain optimism and hope every January, February as we embark on a brand new year and we don't know what's in store.
 
 Julie Abdalla:
 Always. I mean, we do have to keep that hope alive throughout the year, but yeah, absolutely, it's going to be a big year. Very much looking forward to it.
 
 Robyn Jacobson:
 And I look forward to working with you and the rest of our tax policy advocacy team.
 
 Julie Abdalla:
 Yeah, likewise. Hopefully, we'll get you up to Sydney more often this year.
 
 Robyn Jacobson:
 Well, I hope so. I want to stand in front of a live audience, so I do look forward to that. No, thank you so much for your time, Julie.
 
 Julie Abdalla:
 Thank you for having me on the podcast.
 
 Robyn Jacobson:
 We'll get you back again this year, so don't think this is your last appearance.
 
 Julie Abdalla:
 Thank you.
 
 Robyn Jacobson:
 Thank you for listening to this episode of TaxVibe. I've been chatting with Julie Abdalla, FTI, tax counsel at The Tax Institute. To keep up to date with TaxVibe, be sure to subscribe, rate and review wherever you listen to your podcasts. If you'd like to connect with us on social media, follow The Tax Institute on LinkedIn, Facebook, Instagram and Twitter. You can join the conversation on our member only community forum at community.taxinstitute.com.au. Not a member of The Tax Institute? Join a collective voice of 15,000 practitioners at the heart of the profession and find out what the best tax professionals have in common. Join before 28th February 2022 and save 50% on membership. For more information, visit taxinstitute.com.au/membership. You can also contact us by emailing taxvibe@taxinstitute.com.au. We look forward to you joining us next time.