Your client comes to you for advice after reading the following newspaper article about a famous English billionaire and his family's involvement in a Court matter relating to his lawyer's tax affairs Delia Flintstone (wife of Freddie Flintstone, the UK horse racing billionaire) made gifts of 40 million to their tax lawyer, Stephen Milton over a period from 1999 to 2013. Mr Milton claimed that Delia acted like a rich aunt and that the 40 million was a 'thank you wholly outside and distinct from any work relationship'. His barrister suggested that these gifts were quite common among people of Delia's type and class. Rich people usually give large presents to their close friends for no particular reason. The Court found that these payments were actually 'remuneration for services to the Flintstone family interests.' The initial payment of 2.5M was paid as an inducement to Mr Milton to resign from his partnership and provide services exclusively to the family as the family tax lawyer. Three further payments totalling 35M were treated as disguised remuneration even though part of the payment (20%) was made to Mr Milton's wife. A copy of the following letter from Delia Flintstone to Mr Milton was provided to the Court: Dear Stephen Over the years, you have provided services to me and my trusts and you have been well rewarded for what you have done. Over and above this, you have exhibited great friendship to me for which I have been very grateful. Our financial circumstances are very different and I wanted to help your family. In 2006, 2007 and in 2008, I accordingly made gifts to you. The sums paid were gifts and were unsolicited, were made to help you and your family and were not rewards for services. I just wanted to help you. Yours sincerely (signed) Delia Flintstone. Delia also made a gift of 2.5M in of uncut diamonds to Mr Milton which the Court treated as disguised remuneration. The Court found that the gifts coincided with Mr Milton successfully restructuring Mr Flintstone's horse racing business in several overseas trusts as a result of which Mr Flintstone escaped a significant UK tax liability on the disposal of the business. The HMRC, the UK tax authority, advised Mr Milton that he had to pay a significant amount of tax on these amounts. Mr Milton took the HMRC to Court. 4 However, the HMRC did accept that a payment to Mr Milton of 187,500 by the Flintstones towards a holiday in the Maldives was a genuine gift and outside the scope of remuneration as a demonstration of goodwill towards Mr Milton's family wellbeing. Required: How would the Australian law apply to this fact situation? What legal issues would need to be considered? Would the outcome be the same? Refer to relevant legislation and case law.