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outline the transactions that the ATO is concerned about and set out the characteristics of those transactions that will attract ATO attention; 2. tell taxpayers when they need to check whether the circumstances of the transaction are exceptional enough to warrant testing under the reconstruction power; 3. provide bright line tests (if a transaction meets both 1 and 2 above) to enable taxpayers to readily determine if exceptional circumstances exist to require them to use the reconstruction power; 4. make it clear that unless a transaction meets both one and two above, there is no need for them to do anything other than apply what is described in the Draft Ruling is the basic rule.