Geoff is an injured person who, as part of a structured transaction, receives a tax-exempt pension for bodily injury. The pension has a guarantee period of 10 years from the date of invoice.  For discussion of some of the issues raised by requesting tax information and negotiating a transaction, see M Hines, “The Impact of Capital Gains Tax on Damages” (2002) 31 Australian Tax Review 233, 239-40. More recently, the Bundesgericht examined the rules of the dibb proceedings against the Federal Tax Representative.  The taxable person`s employment relationship ended in 1996, but Dibb protested on the grounds that it was illegal, harsh, unfair and unreasonable. He brought an action before the Queensland Industrial Relations Commission and then before the Bundesgericht. Annuity allowances and the immediate lump sum are exempt from tax if they are received on his behalf by Chris` agent. With regard to labour-related disputes, it appears that the provisions of the FTE work advantageously if, otherwise, the obtaining of the transaction had been taxed as ordinary income, although the amount of the concession has been reduced since the 1983 amendments. However, if the ETP contains elements that would otherwise not be recoverable, the provisions of the FTE shall require proof of this, and this effect has been exaggerated since the repeal of Article 26(d) . .