From: Terry Harding [mailto:terryharding@cem.org.au] 
Sent: Friday, 12 August 2011 8:38 PM
To: NFP Reform Consultation
Subject: Submission - Exposure Draft - 'In Australia' Special Conditions for Tax Concession Entities

To whom it may concern:
I am writing to present a submission re the Special conditions for Tax Concession Entities.
As I read the proposed changes, I see that there will be consequences to the freedom that churches will have for distributing funds to non-approved entities.
I see this as not only a limitation of freedom, but also a limitation of the flow of funds to needy groups overseas who are non-approved. 
To my mind, the proposed changes may mean that to retain its Tax Concession Charity (TCC) status, a church would be prevented from giving to overseas missions work, unless the organisation to which it is giving is a TCC, principally doing its work (>50%) in Australia. 
Thus if a church with TCC status wanted to give to a group based overseas it basically couldn't do so, if it wants to retain its TCC status. This is a major change from the current position. 
Here are a few simple questions that I believe need to be answered:
•	How would this affect the freedom a church has to give finances to a needy individual, who walks through the door?
•	How would this affect the freedom a church has to give finances to whomever it chooses, especially an overseas entity? 
•	How is the ATO going to police this law?   
I would like these changes to be discussed in a more open manner, as I was only made aware of them in my organisation yesterday, as I do no trawl through the internet looking for ATO proposed policy changes. I would like to see more consultation with stakeholders such as churches, which will be dramatically affected should the changes become law.

Kind regards,

Terry Harding 

General Manager - Schools Department
Christian Education Ministries 
Ph. +61 7 3881 5744
Fax. +61 7 3881 5792