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1. Minister refers joint report of the Institute and Deloitte on Entity flow-through taxation regime for SMEs to Australia's Future Tax System Review
On 11 June, the Minister for Small Business, Dr Craig Emerson announced that the Government will consider two new measures to simplify small business taxation and reduce small business compliance costs.
One of the measures is the Entity flow-through (EFT) taxation regime developed jointly by the Institute and Deloitte. This has been referred to the review of Australia’s Future Tax System, headed by Treasury Secretary Ken Henry, for their consideration.
The other measure is the Business Activity Statement (BAS) Easy option for simplifying GST bookkeeping for small business. This measure has been referred to the Board of Taxation to consider as part of the Board’s overall review of the legal framework for the GST (refer item 2).
The Institute has long advocated for simplification of tax laws and easing of the compliance burden particularly for small and medium enterprises (SMEs). Our latest work in this area was the EFT submission which was released on 30 April this year. We are very pleased that the Government is already considering it as a viable option.
The EFT regime treats small and medium enterprises as partnerships, that is, ignores the operating entity and taxes the profits in the hands of the owners of the business. The regime is proposed as an option for small companies and unit trusts with five or fewer shareholders wanting to reduce their compliance costs. For more information on the proposed EFT taxation regime, refer to Edition 16/2008 of the Tax Bulletin.
The relevant Minister’s press release is available here.
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2. GST administration review referred to the Board of Taxation
On 11 June, the Assistant Treasurer, the Hon Chris Bowen MP, has asked the Board of Taxation to review the legal framework for the administration of the GST, including Labor’s BAS Easy. The Assistant Treasurer said that he has asked the Board to consult with stakeholders, including small and large businesses, professional bodies and State and Territory Governments, and to report back to him by the end of December 2008.
The review will be focused on:
- Streamlining and improving the operation of the GST;
- Reducing compliance costs; and
- Removing anomalies
However, the review will not extend to either the rate of the GST or the scope of goods and services that are subject to GST.
The terms of reference of this review are contained in the press release and a copy of which is available here.
The Institute welcomes this review for which it has been calling for sometime. Most recently it was requested in our pre-budget submission.
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3. IGOT’s review of GST audits for large taxpayers completed
On 11 June, the Assistant Treasurer, the Hon Chris Bowen MP, released the Inspector-General of Taxation’s (IGOT) report Review of the Tax Office’s administration of GST audits for large taxpayers.
The institute lodged a submission with the IGOT in relation to this review. This submission can be viewed here.
The IGOT recommendations to the ATO include:
- fully remitting general interest charge on revenue neutral transactions; and
- reviewing its past remission of the general interest charge in voluntary disclosures cases by large taxpayers (those which have an annual turnover of more than $100 million).
The ATO agreed with most of the IGOT’s recommendations. Mr Bowen said that the ATO acknowledges the need for more detailed and transparent reporting of the nature of its GST audit results in the large market and the need to improve its approach to cases dealing with margin scheme valuation issues.
The IGOT also recommended that the Government consult with the community on the need for legislative change concerning remission of general interest charge in revenue neutral situations and address undesirable behaviour through the imposition of a penalty. In response to this, Mr Bowen said that he has asked the Board of Taxation to consider the merits of this recommendation as part of the review of the legal framework for the administration of the GST which he has also announced on the same day (refer item 2).
The Assistant Treasurer’s press release is available here.
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4. Intra-group finance guarantees and loans - ATO discussion paper
On Friday 13 June, the ATO released a discussion paper entitled 'Intra-group finance guarantees and loans - Application of Australia’s transfer pricing and thin capitalisation rules'. The purpose of the discussion paper is to facilitate consultation as part of the process of developing an ATO view on the application of Australia’s transfer pricing rules in Division 13 of the ITAA 1936 and the Associated Enterprises Article of Australia’s tax treaties to intra-group finance guarantees and loans.
Comments on the discussion paper are due by 15 July 2008 and we understand that the next step will be for the paper to be discussed at the next NTLG - Transfer Pricing meeting which is scheduled for 22 July.
If members have any comments on the discussion paper, please email us at mailto:taxgroup@charteredaccountants.com.au by Friday 4 July.
The discussion paper can be accessed here.
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5. The Institute meets with the Board of Taxation on the Review of the anti-deferral regime
As reported in Edition19/2008 of the Tax Bulletin, on 19 May, the Board of Taxation released issues papers on possible reforms to Australia's foreign source income anti-tax-deferral regimes. Following this, the Institute participated in a consultative forum with the Board of Tax on these issues papers as reported in Edition 21/2008 of the Tax Bulletin.
On Wednesday 11 June, the Institute, represented by Ann Previtera (PwC), Chair of the Institute’s International Tax Committee, Jenny Wong (KPMG) and Ali Noroozi, Institute’s Tax Counsel, met with the Board of Tax for a more targeted consultation. The discussion focused on the active investment and public company exemption, as well as identification of interests. The Institute, once again, reiterated that whilst it was important to develop appropriate recommendation, it was also important that the Board finalise its recommendations as soon as possible.
As previously reported, the Institute will be lodging its submission on the issues papers later this month.
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6. Lodgment Working Group meeting
A Lodgment Working Group meeting was held on 13 June. An update on the PAYG withholding closely held lodgement concession was provided at the meeting. Other topics discussed included:
- the small business electronic calendar;
- status report of the tax agent client list cleansing project;
- debt collection activities and strategies;
- budget announcement in relation to the administration of Family Tax Benefit and the impact on income tax return lodgement; and
- the ATO’s practices impacting on tax agents meeting lodgement obligations.
Once the draft minutes of the meeting are approved they will be published on the ATO website and a link provided in the Tax Bulletin.
If members would like any further information regarding the matters discussed at the meeting please email us at taxgroup@charteredaccountants.com.au.
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7. Advice Working Group meeting
A meeting of the Advice Working Group was held on 12 June. The following items were covered during the course of the meeting:
- Professional to Professional service guidelines.
The aim of the professional to professional service is to provide direct access to a senior ATO tax manager who will assist a tax practice to resolve exceptional technical issues. The service provides the opportunity for a conversation to be had about technical issues where it is considered necessary to develop a better understanding of the ATO’s view, legislative requirements or prior to requesting a private binding ruling.
- Improving the ATO website and providing a guide to technical assistance to help staff research technical issues
- Enhanced private binding ruling process.
The ATO is looking to improve the ways they currently handle private binding rulings (PBR). One of the options currently being considered is to hold a pre-PBR discussion where the PBR is of a complex nature so that potential issues, research and structure of the PBR request can be discussed before it is actually lodged.
- Practice management reports where the aim is to help manage a practice and its relationship with the ATO.
Once the draft minutes of the meeting are approved, they will be published on the ATO website and a link provided in the Tax Bulletin.
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8. Supplementary submission on draft ruling
The Institute, together with TIA have lodged a supplementary submission, available on the Institute website, on the following draft Taxation Ruling. This is in addition to the Joint Professional Bodies Submission lodged Friday 6 June 2008.
TR 2008/D3 - Income tax: the taxation treatment of ship and aircraft leasing profits under the ships and aircraft articles of Australia’s tax treaties.
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9. Expert evidence not admissible - Ashwick (Qld) No 127 Pty Ltd v Commissioner of Taxation [2008] FCA 853
The Federal Court (Ryan J) has declined the Commissioner’s application to introduce into evidence two affidavits by expert witnesses, as the expert evidence was not relevant to the ultimate question of whether a company in the (former) Elders Group was engaged in ‘a business of lending money’ within the meaning of the relevant provisions of the time in either the ITAA 1936 or ITAA 1997.
The matter forms part of the larger issue under consideration by the court of ‘whether, at any time to which the taxation assessments in question relate, EFG Australia Pty Ltd carried on “a business of lending money,” and whether loans made to Elfic Pty Ltd and EFG Securities Pty Ltd were made in the ordinary course of such a business’.
The court considered that establishing the meaning of expressions like ‘treasury business’ ‘treasury activities’ or ‘cost centre’ by the expert witnesses was not relevant for resolution of any of the ultimate questions for determination in the case.
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10. Decision not to grant release for serious hardship not reviewable - Anderson v Commissioner of Taxation [2008] AATA 478
The Tribunal has dismissed the applicant’s application for review of a decision to grant release from an administrative overpayment.
The Tribunal observed that Division 340 of Schedule 1 of the Tax Administration Act 1953 allows the Commissioner to grant an individual or the trustee of the estate of a deceased person, release from certain tax liabilities in whole or in part, if satisfying those liabilities would cause serious hardship. However, ‘the types of specified liabilities for which release can be granted are explicit and exhaustive’ (in section 340-10) and the Tribunal was of the view that it was clear that the taxation liability from which the applicant was seeking release arose from an administrative overpayment which could not be the subject of release.
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11. No diesel fuel off-road credit allowed - Commissioner of Taxation v Ostwald Bros Civil Pty Ltd [2008] FCAFC 99
The Full Federal Court has allowed the Commissioner’s appeal and set aside a decision of the Administrative Appeals Tribunal, finding that an energy grants credit in respect of the construction of a rail line and access road to carry minerals from a mine site to a port should be disallowed.
The respondent, Ostwald Bros Civil Pty Ltd as trustee for Ostwald Bros Family Trust, had claimed entitlement to an off-road credit for use of diesel fuel. The court concluded that the definition of ‘mining operations’ in Energy Grants (Credits) Scheme Act 2003 did not cover the activities (being the construction of earthworks for a rail line and associated maintenance road) as construction of the rail line was not an activity ‘in the preparation of a site to enable mining for minerals to commence’.
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12. Taxation Ruling – Notice of Erratum
TR 2008/3ER - Notice of Erratum - Income tax: debt/equity - identification of any 'effectively non-contingent obligation' of an issuer of a convertible note to provide 'financial benefits' for the purposes of Division 974 of the Income Tax Assessment Act 1997 if the note can be converted at any time at the issuer's discretion into shares that are equity interests in the issuer company
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13. Draft Goods and Services Tax Rulings
GSTR 2008/D2 - Goods and services tax: general law partnerships and the margin scheme
The Institute will be preparing or co-ordinating the preparation of a submission to the ATO in respect of this Draft Goods and Services Tax Ruling. If you have any comments please e-mail them to us at mailto:taxgroup@charteredaccountants.com.au by 15 July 2008.
Draft Addendum
GSTR 2003/13DA - Draft Addendum - Goods and services tax: general law partnerships
Partial Withdrawal
GSTR 2003/13PW - Partial Withdrawal - Goods and services tax: general law partnerships
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14. Class Rulings
CR 2008/41 - Income tax: BT Investment Management Limited - Employee Equity Plan
CR 2008/42 - Income tax: proposed return of capital: Equities and Freeholds Limited (previously Goldlink GrowthPlus Limited)
CR 2008/43 - Income tax: conversion by Mackay Sugar Co-operative Association Limited to a company registered under the Corporations Act 2001
Withdrawal
CR 2007/58W - Income tax: conversion by Mackay Sugar Co-operative Association Limited to a company registered under the Corporations Act 2001
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15. Product Rulings
PR 2008/56 - Income tax: KTC Mahogany Project 2008 (2008 Participants)
Addendum
PR 2008/3A1 - Addendum - Income tax: Australian Bight Abalone Project 2008
Withdrawal
PR 2007/76W - Notice of Withdrawal - Income tax: Palandri Global Supply Challenge 2007 - 2008 (2008 Growers)
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16. ATO Interpretative Decisions
ATO ID 2008/86 - GST and the supply of a residential care facility by way of a lease
ATO ID 2008/87 - Fuel Tax Credits: Refrigerated Containers (Reefers) - integral mechanically-driven compressor
ATO ID 2008/88 - Fuel Tax Credits: Refrigerated Containers (Reefers) - integral mechanically-driven compressor - application of the road user charge
ATO ID 2008/89 - Excess concessional contributions tax: notional taxed contributions - non-accruing member
ATO ID 2008/90 - Superannuation contributions: return of fund capped contributions by self-managed superannuation fund
Withdrawals
ATO ID 2001/91 (Withdrawn) - Overtime meal expenses
ATO ID 2001/229 (Withdrawn) - Deduction - agency fee paid to overseas company for services
ATO ID 2002/190 (Withdrawn) - Expenses in connection with adoption of child
ATO ID 2002/209 (Withdrawn) - Deductibility of rents and utility expenses by employee on premises owned and used by employer
ATO ID 2002/210 (Withdrawn) - Low-Income Tax Offset - eligible termination payments (ETP)
ATO ID 2002/212 (Withdrawn) - Derivation of income - Monies retained in maintenance reserve
ATO ID 2002/247 (Withdrawn) - Partnership deductions - necessary connection to assessable income
ATO ID 2002/329 (Withdrawn) - Family Tax Assistance - family agreement with spouse
ATO ID 2002/390 (Withdrawn) - Deductions - expenses incurred during volunteer work
ATO ID 2002/404 (Withdrawn) - Derivation of income - premiums held by Options Clearing House
ATO ID 2002/425 (Withdrawn) - Deduction for meals against Sleepover Allowance
ATO ID 2002/464 (Withdrawn) - Deductibility of payment to spouse - not incurred in earning assessable income
ATO ID 2002/868 (Withdrawn) - GST and membership subscriptions to non-residents
ATO ID 2002/1116 (Withdrawn) - Borrowing costs - Lenders Mortgage Insurance
ATO ID 2003/30 (Withdrawn) - GST and preparation of special export documents
ATO ID 2005/247 (Withdrawn) - GST and accounting services supplied to a non-resident owner of Australian residential rental properties
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17. Taxpayer Alert
TA 2008/12 - Non-cash contributions to superannuation funds
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18. House of Representatives’ draft legislation program
Federal Parliament will resume sitting next Monday 16 June. The House of Representatives has released its Draft Legislation Programme Winter Sittings for the period 16 to 19 June and it is expected to resume debate on the following tax related Bills:
- Tax Laws Amendment (Election Commitments) – 17 June
- Income Tax (Managed Investment Trust Withholding Tax) – 17 June
- Income Tax (Managed Investment Trust Transitional) – 17 June.
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19. Senate’s revised draft legislation program
The Senate has released its Revised Draft Legislation Program for the period 16 to 20 June and it is expected to resume debate on the following tax related Bills:
- Tax Laws Amendment (Personal Income Tax Reduction) Bill 2008 - 16 June
- Tax Laws Amendment (2008 Measures No. 2) Bill 2008 - 16 June
- First Home Saver Accounts Bill 2008, Income Tax (First Home Saver Accounts Misuse Tax)
Bill 2008 and First Home Saver Accounts (Consequential Amendments) Bill 2008 - 17 June
- Tax Laws Amendment (Medicare Levy and Medicare Levy Surcharge) Bill 2008 - 17 June
- Tax Laws Amendment (Election Commitments No. 1) Bill 2008 - 19 June
- Tax Laws Amendment (2008 Measures No.1) Bill 2008 subject to committee report - 19 June.
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20. Recent ATO publications
Booklets and publications
Demutualisation of MBF - This information applies to you if you had a private health insurance policy with MBF on 8 November 2007 and receive a payment of cash under the demutualisation of MBF which is proposed to take place on 16 June 2008.
Information for primary producers 2008 - A primary producer is an individual, a trust or a company carrying on a business of primary production. NAT 1712-6.2008
Save money on your business fuel costs - From 1 July 2008 fuel tax credits will be expanding which means more businesses than ever will be able to reduce their business fuel costs.
Shortfall interest charge (SIC) rates - Update to include shortfall interest charge (SIC) rates announced for the first quarter of the 2008-09 income year.
Freedom of information requests
Freedom of information request - liquidators - A guide for liquidators seeking access to documents (Nat 71959)
Freedom of information request - A guide for people seeking access to documents. (NAT 2877)
Minutes of meeting
NESB Community Advisory Group Forum minutes - 10 April 2008 - Minutes of the NESB Community Advisory Group Forum held on 10 April 2008.
Superannuation
Paying super - your handy reference - This publications provides an overview of superannuation obligations for employers.
Contributions to superannuation funds under scrutiny - The Tax Office today issued a taxpayer alert warning trustees and members to be cautious when moving assets other than cash into superannuation funds.
Self managed superannuation fund annual return 2008 instructions - For use by self managed superannuation funds to assist in completion of 2008 annual return. NAT 71606-6.2008
Super benefits from a taxed source - Guide for super professionals - This guide (NAT 71952, PDF, 336KB) introduces the new arrangements from 1 July 2007 that affect super benefits paid from a taxed source.
Self paced learning guides for super professionals - This guide explains new arrangements for paying a super benefit from 1 July 2007.
Superannuation spouse contribution tax offset - Explains who can claim a tax offset for contributions on behalf of a spouse with a low income, and how to work out a claim.
Key superannuation rates and thresholds - Key superannuation rates including AWOTE, superannuation guarantee, contribution caps, co-contributions, employment termination payments (ETP) and super benefits.
Administration
TaxPack 2008 supplement - The TaxPack supplement contains information about income tax questions which apply to relatively few taxpayers. NAT 2677-06.2008.
Individual PAYG payment summary schedule 2008 - For use by individuals to assist with completion of 2008 income tax returns. NAT 3647-6.2008
Individual income tax return 2008 - 2008 individual income tax return for tax agents and information on ordering paper copies. NAT 1371-6.2008
Company income tax return instructions 2008 - For use by companies to assist with completion of 2008 tax returns. NAT 0669-6.2008
Research and development tax concession schedule instructions 2008 - For use by companies to assist with research and development deductions on the company tax return for 2008. NAT 6709-6.2008
Lodging your 2007-08 tax return - From 1 July 2008 you can lodge your tax return for the 2007-08 financial year.
Rental property deductions - know what you can claim - Over 1.5 million people claimed more than $24 billion in rental deductions in their tax returns last year, with almost 170,000 people claiming deductions for the first time.
Tax help in times of extreme weather and hardship - The Tax Office knows extreme and unpredictable weather conditions such as droughts, floods, bushfires and storms directly affect the income of many people in rural and regional communities.
Tax Office help to lodge 2007-08 tax return - audio news release - English language audio news grabs can be downloaded as MP3 files.
Work related expenses - what you can claim in 2008 - Of the 11.5 million people who lodge a tax return each year, more than seven million claim deductions for work-related expenses.
FTB
Family tax benefit short (FTB) tax claim instructions 2008 - This information will help you to work out your entitlements to family tax benefit and to complete a claim for lodgment with the Tax Office. NAT 4108-6.2008
Family tax benefit (FTB) tax claim 2008 - This form can be used to make a claim with the Tax Office for family tax benefit. The guide contains the short and long claim forms as well as instructions for both. NAT 4117-6.2008
Family tax benefit (FTB) short tax claim 2008 - The short tax claim can be used by people with relatively simple claims for family tax benefit. NAT 4153-6.2008
Baby bonus claim 2008 - Use this form to claim the baby bonus if you gave birth to a baby or gained legal responsibility of a child aged under 5 (for example, through adoption) on or after 1 July 2001 and prior to 1 July 2004. NAT 6581-6.2008
Baby bonus instructions and claim 2008 - Use this form to claim the baby bonus if you gave birth to a baby or gained legal responsibility of a child under 5 (for example, through adoption) on or after 1 July 2001 or prior to 1 July 2004. NAT 6580-6.2008
CGT
Capital gains tax update 2007-08 income year - Update on CGT developments for the 2007-08 income year. Current as at 31 May 2008.
Capital gains tax focus for 2007-08 tax returns - The Tax Office will continue to focus on capital gains tax (CGT) this year, in particular people who do not report capital gains for the sale or disposal of shares, properties and other assets.
Benchmarks and examples
ATO Industry Benchmarks - Industry endorsed benchmarks for floor sanding and polishing, painting, and roofing.
Floor sanding and polishing benchmarks and examples - Industry endorsed benchmarks for floor sanding and polishing.
Painting benchmarks and examples - Industry endorsed benchmarks for painting.
Partnership and trust tax returns instructions 2008 - For use by partnerships and trusts to assist with completion of 2008 tax returns. NAT 2297-6.2008
Roofing benchmarks and examples - Industry endorsed benchmarks for roofing.
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21. Commissioner’s speech on the cash economy to Council of Small Business of Australia
On 11 June, in a speech addressed to Council of Small Business of Australia (COSBOA) at its National Summit, the Commissioner of Taxation, Michael D’Ascenzo, talked about the cash economy. He said that through unrecorded and unreported cash transactions, the cash economy introduces unfair practices that adversely impact many small businesses.
The Commissioner announced that three benchmarks are being published by the ATO and trade associations. These are for the floor sanding, roof tiling and painting industries. Mr D’Ascenzo said that benchmarks give businesses the opportunity to take an important ‘reality check’ and will provide guidance on the time and materials involved in an average job.
The Commissioner also spoke about extensive use of data matching and other technologies by the ATO to detect unreported cash transactions. He said that this is a high priority for the ATO and to the end of May this year the ATO has conducted close to 2,000 audits directly as a result of its focus on the cash economy.
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22. The Australian National Audit Office released its second Taxpayers’ Charter audit
The Australian National Audit Office (ANAO) has released its second Taxpayers’ Charter (the Charter) audit report Taxpayers’ Charter – Follow-Up Audit, Australian Taxation Office.
The objective of the audit was to assess the ATO’s implementation of the nine recommendations made by ANAO in its first audit. This involved an examination of the ATO’s:
- systems and processes used to develop, maintain and update the Charter;
- strategic commitment to implementing the principles of the Charter;
- integration of Charter principles with its business processes;
- systems for resolving disputes according to Charter principles; and
- monitoring and reporting of its performance against commitments in the Charter.
The report concluded that the ATO has progressed well in implementing these recommendations, implementing all recommendations in full or part. The ANAO made four recommendations during the course of conducting the current audit, to improve the ATO’s management of its responsibilities under the Charter.
The ATO agreed with all of the recommendations though it has qualification on three.
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23. Taxation Ombudsman activities report 2007 released
The Commonwealth and Taxation Ombudsman, Prof. John McMillan issued a media release on 11 June, announcing the release of the 2007 taxation activities report. The report highlights the practical assistance the Ombudsman’s office provides to taxpayers in resolving their difficulties with the ATO.
Mr McMillan said that the report outlines particular problem areas that emerged over the year, such as debt collection activities, non-payment of superannuation guarantee, provision of adequate information, the imposition of penalties, and lodgement and processing difficulties. Another focus is complaint trends and the Ombudsman’s project work program that addresses underlying problem areas.
In responding to the report, the Commissioner of Taxation noted his work with the Ombudsman in development of best practice in areas such as dispute and complaints resolution, good governance and a general framework of administrative rights that provides wide ranging protection for taxpayers.
A copy of the report is available here.
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24. ATO reminds taxpayers to start thinking about preparing and lodging 2008 tax returns
On 10 June, the ATO issued a press release reminding taxpayers to start thinking about preparing and lodging their 2008 tax returns. The Commissioner, Michael D’Ascenzo said that e-tax is a user-friendly and secure way to lodge returns and it has even more new features this year.
E-tax can be downloaded from the ATO’s website 24 hours a day, 7 days a week from 1 July, and Government and third party information will also be available to download progressively from 1 July.
However, taxpayers can still use lodge paper returns this year and those who lodged this way last year will receive a copy of TaxPack 2008 in their letter boxes, starting from next week. For those taxpayers who anticipate to use tax agent this year for the first time or those using a different agent to last year, the Commissioner reminded that they must contact their agent by Friday 31 October 2008.
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Chartered Accountants Tax Seminars for Practice
Friday, 20 June 2008, Melbourne. Complete guide to Small business CGT concessions, GST and ‘Supply of a going concern’, GST and ‘Margin scheme issues’ and more.
Chartered Accountants New Employees Taxation Workshop
Throughout July and August in Sydney, Brisbane, Melbourne, Adelaide and Perth. This intensive two day workshop will provide new employees with the taxation skills and understanding needed to improve productivity in the early stages of employment.
Chartered Accountants Tax Atlas Series
A reference tool that assists in identifying key issues, understanding of key concepts and provisions. Available now: Tax & Wealth Creation; FBT & Salary Packaging; Small Business CGT Concessions.
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One member writes
I note that the ATO is engaging debt collectors to recover debts.
This morning, we received a debt collection notice for $200.48 from a company called 'Recoveries' with whom we have not had dealings before. The letter dated 5 June 2008 was received on 11 June 2008 and gave the taxpayer 7 days to pay this large debt. So if I could not find the taxpayer, quite likely that they were away in a short week, we could not comply and in the event that they were not away my client had 24 hours to come up with the money. Why does the ATO and the people it chooses to contract with not use common sense when there are short weeks and allow for the fact that the post will be slow and that there are not 7 working days available.
What is even more amusing in this case is that I will be lodging the return for the taxpayer in about 4 weeks time, it will more than likely result in a refund as the taxpayer is PAYE with no investments and the ATO could have actually received $200.48 net, rather than the .48 net that will probably be received after the contractor has been paid! Whilst understanding that the ATO needs to collect debts, surely a little common sense should be applied with these small debts and perhaps a phone call rather than threatening letters and impossible time frames would make life easier for all concerned. I should add that we have had no previous contact concerning this client.
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