Please refer to the attachment. I would like you to approach the assessment as a professional letter to the client addressing his resident of Australia for tax purposes and his assessment for his tax...

Please refer to the attachment.
I would like you to approach the assessment as a professional letter to the client addressing his resident of Australia for tax purposes and his assessment for his tax income (higher tax than resident of Australia for tax purposes).


Note: I understand the word count would be consumed by reciting case law and Income Tax Assessment Act 1936, I would really appreciate you are able to focus on discussing side of the question and please attach the references used (Exclude it from your set 750 word limit, if possible).


Doowon Choi is a 24 year old citizen of the Republic of Korea who is single with no dependants. He is a promising football star having played professional football in South Korea with Suwon Blue Wings F.C. and the Under 20 national team. In December 2019 Doowon signed a contract to play professional soccer for the Newcastle Jets F.C., a club playing in the Australian Premier League. The contract is for the six month Australian professional season (1 March 2020 to 31 August 2020) with an option to extend for the following season if both parties agree. In accordance with the contract Doowon will arrive in Australia on 1 February 2020 to commence training ahead of the season opening in March 2020. Doowon has purchased a one-way ticket to Sydney departing Seoul on 28 January 2020. While in Newcastle he will reside in an apartment overlooking Newcastle beach which he has leased for six months. He has a further six-month option to rent the apartment if his contract with the Jets is extended. While in Australia he will lease the fully furnished apartment he owns in Korea to friends. His mother and father will store his personal possessions (including his football trophies) at their home in Seoul. Doowon is confident he can make a career as a professional soccer player. If the Newcastle Jets contract is not renewed in September 2020 he intends to engage an agent to secure a contract with another football club either in Australia or elsewhere in the world. Required: In the form of a professional correspondence, advise Doowon on whether he will be classed as a resident of Australia for tax purposes at 30 June 2020. Also advise Doowon how his residency classification will affect the Australian taxation treatment of his contract income from the Newcastle Jets.