I'm assuming that most people have actually read the terms of the original freezing order of Moshinsky J? If not, it clears up some contentious matters here.
I don't know enough about the global tax arrangements of the individuals and the associated corporate entities to comment on the correctness or otherwise of the assessment of the ATO. That said, there are paragraphs that jump out if anyone is labouring under a misapprehension of what is squarely in the cross-hairs, and from what I've seen to date, the Commissioner, rightly or wrongly, seems fairly robust on that unencumbered figure.
https://www.comcourts.gov.au/file/Federal/P/VID580/2021/3924399/event/30851334/document/1848962
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