The recent activities of the ATO with Operation Wickenby bring a stark reminder to tax advisors that the ATO won't be far behind in targeting dubious tax schemes that seek to venture ‘over the line'. This paper reviews key Wickenby issues for tax advisors such as legal professional privilege, the privilege against self incrimination and the courts' attitude towards tax criminals by reference to:
- the stockaders - who are the targets?
- the troopers and their ammunition
- armed resistance - LPP and privilege against self incrimination?
- the casualties - analysis of the sentencing of Wheatley
- a brutal over-reaction or legitimate enforcement?