Where a sentencing judge finds that tax fraud falls into the worst category of offences under s 135.4(5) of the Criminal Code (Cth), the sentence must reflect that finding and should be at or close to the maximum penalty absent significant mitigating subjective circumstances. Sophisticated money laundering involving offshore transfers through controlled entities and false identities involves distinct and additional criminality beyond the predicate fraud offence, requiring significant accumulation rather than substantial concurrency. The overall sentence of 14 years (9 years for the tax fraud conspiracy plus 12 years for the money laundering conspiracy with partial accumulation) was appropriate for offending involving intended losses of $135 million and personal gain of $19.6 million.
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