It's obvious he's put in some effort to minimise his taxes,...

It's obvious he's put in some effort to minimise his taxes, which isn't illegal. However, whether that was through his personal effort or advice from his tax agent(s) is another matter.

The fact that his legal team has raised the 2-year limit suggests they believe it will be difficult for the ATO to prove they can still collect the money.

The outcome will be interesting to watch considering judgements are based on law, not feelings or opinions of what the “right thing” should be. This reminds me of the job keeper payments debate.