Dear Sir.

The Board of Homes of Hope International has noted with deep concern the proposed changes to the legislation regarding the 'In Australia' Special Conditions for Tax Concession Entities and wishes to express how potentially damaging the changes will be to those who have no voice but are the recipients of the hard work of Homes of Hope International on their behalf.

Firstly, there was very little time given for small NFP's like HOHI to consider this legislation and to seek legal opinion in order to exegete the intent and meaning of the proposed changes. 

Secondly, we are concerned about words like 'restate' as in "legislation that will restate the 'in Australia' special conditions for tax concession entities". The intent seems to be not one of 'restating' but of abolishing the good work done by many NFP's. This has very serious implications for the recipients of programmes HOHI partners with.

It seems to us that the proposed changes will completely alter the basis on which tax exemption is granted from 'character and purpose' to 'type of organization you interface with'. Such a myopic view that is unable to see beyond our own shores that is astounding.

Furthermore in our view the "double dipping" tax intent in the proposed changes is unprincipled, unfair, and discriminatory. Homes of Hope International does not enjoy tax deductible status, and our donors suffer this discrimination because they understand the qualitative outcomes achieved by their donations. To then propose that their donations be taxed again seems unconscionable.

Homes of Hope International works with partner organizations in rescuing women and children at risk. We are an organization that was started by Aussies to address a niche need which other organizations are not addressing. Our donor sponsorship programme has seen hundreds of lives impacted and changed. We have worked hard to ensure the recipients of our endeavours break the cycle of poverty.

Fifthly, it would shameful for the Australian public to be denied the opportunity of contributing to transformative projects because of the bewildering lack of understanding by the tax department and legislature of the basis on which many wonderful organizations exist and work. It seems inconceivable that Treasury would endeavour to make it difficult for good-hearted Aussies to have a go and to contribute to worthwhile projects that transform lives. 

We say that this legislation is at the very best ill conceived. For HOHI it will be restrictive and as such is both unreasonable and unfair. It will be hugely disadvantaging to us, and at the end of the day countless people will suffer because of your proposed changes. 

We agree with others who say that "this legislation is far too qualifying on the way in which funds can be applied overseas and seems determined to defund civic society", the very group who will ultimately produce good and lasting transformative development of the type your government says it wants to see.

We humbly submit that you withdraw and reconsider the legislation after talks with representative groups from the NFP sector. 

Homes of Hope International will support those like Mooreslegal who understand much more of the implications of this legislation than simple laypeople like ourselves. 

Yours Sincerely,

Greg Beech

For Homes of Hope International Board of Directors

Help rescue women and children at risk 
http://www.homesofhopeint.com

Greg Beech: +61411124371