Submission to the Treasury Discussion Paper:
Reform to deductions for education expenses
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Contents
Key points..................................................................................................................................................................................................... 2
Introduction................................................................................................................................................................................................. 4
The $2,000 cap is bad economic policy ...................................................................................................................................... 5
The $2,000 cap is inconsistent with basic principles of good tax policy.................................................................... 6
The $2,000 cap causes high effective marginal tax rates.................................................................................................... 7
The $2,000 cap causes effective price rises for postgraduate courses between 30 and 50 per cent ....... 9
The $2,000 cap will cause a large reduction in postgraduate study............................................................................. 9
The $2,000 cap will result in a reduction in future postgraduate productivity ...................................................... 9
The model provides a conservative estimate of negative effects ............................................................................... 11
The cap will cause a large decrease in future production .............................................................................................. 11
The long-term impacts need to be modelled ....................................................................................................................... 12
Government modelling suggests a $6 billion per annum loss ...................................................................................... 13
The losses from the cap grow as a percentage of GDP ................................................................................................. 14
Treasury has not applied its wellbeing framework in analysing the $2,000 cap ................................................. 14
Inconsistency with the principles of the Treasury wellbeing framework ................................................................ 15
An alternative, revenue neutral, proposal ................................................................................................................................ 17
Appendix 1: Some responses from universities and students ...................................................................................... 19
Surveys show a cap on education tax deductions would deter students ......................................................... 19
Science and mathematics teachers are especially hurt by the cap........................................................................ 19
Skills shortages in mental health and counselling exacerbated by the cap ....................................................... 19
Workplace safety negatively impacted by the cap ........................................................................................................ 20
The cap does not fit the fees .................................................................................................................................................... 20
The cap reduces professional up-skilling ............................................................................................................................. 20
Representative examples and quotes from students. .................................................................................................. 21
Submission to the Treasury Discussion Paper: Reform to deductions for education expenses
1
Key points
The proposal to cap education expense deductions at $2,000 per annum is a tax on learning and a
productivity retardant. It is at odds with recent statements made by Government on productivity and
is inconsistent with the Australia in the Asian Century White Paper and with the 2010 Review into
Australia’s tax system that recommended tuition fees be deductible from the first dollar. It is strongly
opposed by Universities Australia and the unanimity of views across all professional groups is
indicative of the shortcomings of this ill-conceived proposal. It should be immediately withdrawn.
The $2,000 cap would:

undermine basic principles of good tax policy: efficiency, equity and simplicity;

result in very high effective marginal tax rates and, by acting as a disincentive for people to
invest in their own skills, knowledge and qualifications, will lead to a substantial decline in
national productivity – a long term GDP reduction of between $2.8 billion and $6 billion per
annum;

be incompatible and fundamentally inconsistent with the Government’s stated objective to lift
national productivity growth by 2 per cent per person per annum.1 Introducing the cap, we
calculate, will decrease long term national productivity growth by between 0.2 to 0.4 per cent
per annum;

retard the most important and higher growth sectors of the economy, causing a higher
percentage of GDP to be lost into the future – up to 0.6 per cent per annum;

substantially reduce government income tax revenues. The government Budget balance, we
calculate, deteriorates by between $850 million to $1.5 billion per year in 2013 dollar terms
over the longer term;

undermine the Government’s stated objective to build a diversified, knowledge based
economy underpinned by a highly-skilled and educated workforce. This tax on education will
cause postgraduate enrolments and completions for fee paying students to decrease, at a
minimum, by between 20 and 30 per cent, and will increase the effective cost of courses
generally by between 30 and 54 per cent;

not address the stated objective in the discussion paper, which is to stop private consumption
benefits being claimed as education expense deductions;

represent a view that the costs involved in upgrading qualifications and professional
development to meet work requirements are not legitimate work related expenses. The
discussion paper provides no justification for this;

further disadvantage women, who have high representation in postgraduate education. Further
education is a critical mechanism for women to achieve income equality;

further disadvantage rural and regional communities who generally incur higher costs in
pursuing further education;

disproportionally deter poorer people from undertaking further education – 87 per cent of
self-education expense claims are submitted by people who earn $80,000 or less. 2
1
See Prime Minister Kevin Rudd’s speech to the National Press Club on 11 July 2013. The Prime Minster called for a new
productivity agreement between government, business and unions to lift productivity growth to 2 per cent per year.
2
See ―Reform to deductions for education expenses‖, Treasury Discussion Paper, May 2013 at page 5, hereafter: the
Treasury paper.
Submission to the Treasury Discussion Paper: Reform to deductions for education expenses
2
The policy change is also fundamentally inconsistent with Treasury’s mission statement and core
objective to improve Australia’s wellbeing. It is not apparent that any reference to the Treasury’s
wellbeing framework has been made.
As an alternative, Universities Australia would welcome consideration being given to making the first
$90 of all work-related expenses non-deductible. This proposal would deliver approximately the same
level of savings in the short term, and an increasing level of revenue over the long term, at a cost per
year to the individual taxpayer of no more than approximately $42 and an average of $27.
The welfare losses from raising extra tax revenue under this alternative are near zero, compared with
estimated losses of between $2.8b and $6b per annum under the $2,000 cap.
Appendix 1 to this submission includes a series of case studies, examples, and messages from students
illustrating the profound harm that will be caused should the Government decide to proceed with this
measure.
Submission to the Treasury Discussion Paper: Reform to deductions for education expenses
3
Introduction
Universities Australia (UA) is pleased to provide this submission to the Treasury’s ―Reform to
deductions for education expenses‖ Discussion Paper May 2013.
The central issue in our rejection of the Treasury argument for the proposal to cap annual tax
deductions for self-education expenses at $2,000 is that it introduces a fundamental inconsistency into
the national economic policy framework. On the one hand, the Government has expressed a genuine
desire to move Australia down the path of greater productivity and competitiveness in which a highly
skilled and educated workforce is a key factor. On the other hand, the Government proposes to
abolish one of the most effective mechanisms for achieving this, one that gives individuals a personal
capacity and incentive to invest in their own education, to earn more income, to pay higher taxes and
to contribute to this broader national aspiration.
The Government will be aware of the dismay that has greeted this proposal from practically every
professional association in the country. The response is not just because of the effect on their
members’ personal interests, but reflects a genuine concern that the architects of the proposal are
unaware of, or simply ignored, the broader social and economic implications of the proposal.
This submission proposes that the capping proposal entirely misses the intended target and has both
foreseen and unforeseen impacts on the wider economy. The only explanation offered so far for the
capping proposal is that it will prevent abuse of the tax deductions by individuals who use ―selfeducation‖ as a synonym for a publicly supported holiday in exotic locations. Assuming that preventing
this behaviour is the genuine intention behind the capping proposal, a far more effective and
straightforward intervention would simply negate the ability to claim this type of expense, but would
not target individuals who are genuinely seeking, or are required, to upgrade their skills, knowledge
and credentials.
The scale of the alleged problem has not itself been quantified beyond the estimated short-term
savings from capping the taxation deduction and this, as we show in this submission, is far outweighed
by the actual cost of implementation.
Universities Australia, as the sector’s peak body, has been advised by every member institution of their
deep concern that the capping proposal will result in significant enrolment decline, particularly in
postgraduate courses for fee paying students. This is expected to be in the order of 20 to 30 per
cent.
As an alternative to the proposed cap, we suggest consideration be given to making the first $90 of
work related expenses non-deductible. This would be revenue neutral in the short term, and strongly
revenue enhancing over the long term.
This alternative proposal raises a similar amount of tax revenue at a very small cost to the economy,
estimated at $1 million to $2 million per annum, compared with the multi-billion dollar losses in
productivity and income tax associated with the $2,000 cap.
Many universities have made their own direct submissions to the Government and we commend
these to you in providing institutional specific perspectives and impacts.
Submission to the Treasury Discussion Paper: Reform to deductions for education expenses
4
The $2,000 cap is bad economic policy
A core principle of good tax policy design is that net income, not gross income should be taxed. A
deduction should be permitted for all costs incurred in producing income. This principle acknowledges
that individuals with the same level of income may incur very different costs in earning that income.
The principle is embodied in Section 8-1 of the Income Tax Assessment Act 1997 that allows a
deduction for the costs incurred in gaining or producing assessable income. The principle is critical for
maintaining economic efficiency, and horizontal and vertical equity, as we explain below.
This key principle is recognised at page 1 of the Treasury discussion paper. However, the paper then
proposes a $2,000 cap on deductions for self-education expenses, thus effectively emasculating the
core principle by moving to a system that taxes gross income, less the first $2,000 of expenses, where
self-education costs are involved. The Treasury paper does not explore, or even discuss, the
substantial costs and economic inefficiencies from undermining this basic taxation principle.
The $2,000 cap curtails economically efficient investment in education, causing everyone,
including Government, to be worse off.
A simple example to demonstrate the point is provided in Box 1.
A nurse who earns $55,000 per year is considering undertaking a one year postgraduate course at a
cost of $15,000. The course will make the nurse more productive and skilful. He or she expects that
his or her future income would be increased by $20,000 over their lifetime.3
Everyone is better-off. The nurse completes the course; $5,000 of economic value is created. The
nurse is net $3,300 better off, and the government collects $1,700 of extra taxes from the higher
future income she will earn.
Conversely, with the introduction of the $2,000 cap on education deductions, the nurse will not
undertake the course because she would be $1,120 worse off post tax as shown below. The nurse
also faces a 122 per cent effective marginal tax rate on the extra income she earns from undertaking
the course. The result is economically irrational and fundamentally unjust.
Table 1: The $2,000 cap deters socially beneficial education
Income
Education Expense
Net income
$55,000
$55,000
Education
(No cap)
$75,0004
$15,000
$60,000
Tax
$10,247
$11,947
$16,367
Post tax income
Better/Worse off
$44,753
$48,053
$3,300
$43,633
-$1,220
Nurse
3
No education
Education
($2,000 cap)
$75,000
$15,000
$60,000
The present value of her future income is expected to increase by $20,000.
4
For simplicity, the $20,000 increase in her lifetime income is presented in the table as an increase in her income over one
period from $55,000 to $75,000, with the present value of the rise in future tax payments also calculated over this one
period.
Submission to the Treasury Discussion Paper: Reform to deductions for education expenses
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It should be noted that Australia’s largest health union, the Australian Nursing Federation (ANF), has
warned:
―…the $2,000 cap will negatively impact the self-education, continuous professional
development and postgraduate studies undertaken by Australia’s nurses and
midwives….As a result, safe patient care will suffer if nurses and midwives have limitations
placed on their ability to continually improve their clinical skills and keep pace with new
health technology, pharmaceuticals and treatments. Safe patient care will suffer particularly
in rural and remote communities…
Australia continues to experience an increasing shortage of nurses and midwives right
across the public and private hospitals, nursing homes and mental health facilities, with a
predicted shortage of 109,000 nurses and midwives by 2025….putting a tax like this on
the education of nurses and midwives will only make it worse.‖ 5
The $2,000 cap is inconsistent with basic principles of good tax
policy
The basic principles of good tax policy include:

economic efficiency – tax revenue should be raised in a manner causing the least distortion to
consumer and producer choices;

horizontal equity – people with the same net income should pay the same amount of tax;

vertical equity – people with different incomes should make comparable sacrifices in paying
tax; and

simplicity – the tax system should be as simple as possible to administer.
The $2,000 cap is fundamentally inconsistent with the basic principles that underpin good
tax policy.
Economic efficiency is undermined. Individuals will have little incentive to invest in education because
of very high effective marginal tax rates. The highly distortionary effects of the cap will create a large
contraction in production of at least $2.8 billion each year.
In addition, the policy encourages a shift from investing in skills and education to other fully deductible
items. This is clearly at odds with the Government’s own skills agenda and demonstrated in analyses
by the Australian Workplace and Productivity Agency among others.6
The distortionary impact of the proposal would mean that investing in education would
need to produce returns to the individual of between 30 to 50 per cent more than
investments in other deductible items such as tools and equipment.
Education also produces significant spill-over benefits,7 in contrast to plant and equipment, further
compounding the losses from the $2,000 cap.
5
See Australian Nurses Federation media release Monday 8 June at http://anf.org.au/news/entry/exempt-nurses-andmidwives-from-2000-cap-on-training-expenses.
6
See ―Future Focus, 2013 National Workforce Development Strategy‖, March 2013.
7
More educated people share knowledge with others, which in turn can be re-shared, thereby generating a more
knowledgeable and productive society.
Submission to the Treasury Discussion Paper: Reform to deductions for education expenses
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Other consequences of the proposal include the likelihood of students deferring or slowing down the
pace of study and completion, and universities losing economies of scale from the move to more
fractionalized study. Second and third round welfare losses are elaborated below.
Horizontal equity is undermined. Consider two nurses each with $60,000 of net income, where one
has incurred $15,000 of education expenses to produce that net income. Even though both have the
same net income, the better educated nurse pays $16,367 in tax, or 37 per cent more tax than the
less educated nurse who only pays $11,947. This indicates the unfairness of the policy, from a taxation
perspective, for those wishing to invest in their own education and skills development.
Vertical equity is undermined. As shown in Box 1, the nurse that improves their income from
$55,000 to $60,000 through education, ends up paying $1,120 more in taxes than the increase in
income, leaving them worse off than the person earning only $55,000. People who earn extra income
as a consequence of their investment in education would make disproportionally high sacrifices to the
tax base.
Simplicity is undermined. The $2,000 cap is inconsistent with the fundamental basis of personnel
income taxation that has existed for over 80 years in developed societies, based on the Haig-Simons
definition of net income or changes in net wealth being the economically correct tax base.8 The
$2,000 cap undermines this simple, well accepted and readily understood taxation theory.
The cap will also cause significant and complex distortions where employers who pay for employees’
education may claim tax deductions, except where they form part of salary packaging arrangements.
These complexities and the relative lack of specific detail around the operation of the
measure raise fundamental questions about the veracity of the estimated saving, and the
potential high cost of administering the measure.
The $2,000 cap causes high effective marginal tax rates
Universities Australia has surveyed its 39 member universities on the effects of the proposed $2,000
cap. Members expect the $2,000 cap will have the largest effect in deterring students from enrolling
in fee-paying postgraduate courses.
Postgraduate course costs for fee paying students typically range between $5,000 and $15,000 per
annum, depending on the field of study and the intensity with which the course is completed. Table 2
shows the effective marginal income tax rates on net extra income they can expect to earn from
undertaking further study.
8
See Haig, Robert M. (1921). "The Concept of Income—Economic and Legal Aspects". The Federal Income Tax. New
York: Columbia University Press. pp. 1–28. Simons, Henry (1938). ―Personal Income Taxation: the Definition of Income as
a Problem of Fiscal Policy‖. Chicago: University of Chicago Press. p. 49.
Submission to the Treasury Discussion Paper: Reform to deductions for education expenses
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Table 2: Effective marginal tax rates on extra income derived from self-education
Benefit/Cost ratio of course
Self-education expense per
annum
($55,000 per annum
income)
1.1
1.2
1.3
1.5
2
$5,000
238%
136%
102%
75%
54%
$10,000
306%
170%
125%
88%
61%
$15,000
329%
181%
132%
93%
63%
Row two shows the expected benefit/cost ratio of the course to the student. For example, a ratio of
1.3 shows a course with a cost of $10,000 would be expected to generate $13,000 of future income
benefit to the student, whilst a ratio of 1.5 indicates a benefit of $15,000. All courses where the
benefit/cost ratio is greater than one produce a net benefit to society and should be undertaken.
Rows three to five show the effective marginal tax rate faced by a student earning $55,000 of income
per annum9 with course costs varying per year from $5,000 (Row three) to $15,000 (Row five).
Table 2 shows the following:

The $2,000 cap is a tax on education. Any extra income earned as a consequence of selfeducation and up-skilling would effectively be subject to double taxation, causing very high and
uneconomic marginal tax rates. The rise in the effective marginal tax rate on income earned
via self-education, caused by the double taxation under the cap, is provided by the formula: (Δ
gross income - $2,000)/ (Δ net income).10

Effective marginal tax rates are greater than 100 per cent for all courses where the
benefit/cost ratio is 1.3 or less. So all education courses where $1 of cost produces up to
$1.30 of benefit, or 30 cents of value add to society, will no longer be undertaken because the
student will be worse off.

The student faces very high effective marginal tax rates even where courses have a high
benefit/cost ratio. For example, consider a student undertaking a three year post graduate
degree costing $15,000 per year, with a benefit cost ratio of two, generating $90,000 of
expected extra income, and $45,000 net benefit to society. The student will face an effective
marginal tax rate of 63 per cent (see column five, Row six). Taking account of the significant
effort and time involved in completing the course, it may be unlikely the student will bother
doing the study when she only gets to keep 37 cents for every extra dollar she earns.

The effective marginal tax rate for the student has more than doubled from 34 per cent to 75
per cent or more for all courses where the benefit cost ratio is up to 1.5.

In general, the student faces very high effective marginal tax rates, much higher than the
current highest personnel income tax rate at 46.5 per cent. So the deterrent effect on
9
The $55,000 income level has been chosen to show that people on relatively low incomes will face very high effective
marginal tax rates.
10
The $2,000 cap effectively subjects income derived from self-education to double taxation. In the first instance, the tax
base is (Δ net income), the economically correct tax base. After the $2,000 cap, an additional or second tax is then also
levied on self-education derived income on the base: (Δ gross income – Δ net income - $2,000). The effective increase in
the marginal tax rate = (Δ gross income - $2,000)/ (Δ net income). So if this ratio is 2, for example Δ gross income is
$18,000 and Δ net income is $8,000, the effective marginal tax rate on self-education related income for a person earning
$55,000 per annum rises from 34 per cent to 68 per cent.
Submission to the Treasury Discussion Paper: Reform to deductions for education expenses
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undertaking education from the $2,000 cap is very high, and would be expected to significantly
decrease future enrolments in postgraduate fee paying courses.
The $2,000 cap causes effective price rises for postgraduate
courses between 30 and 50 per cent
The cap causes very large and uneconomic effective price rises for postgraduate courses for fee
paying students. Table 3 shows the effective price rise for typical courses, where the cost ranges from
between $5,000 to $15,000 per annum, for a person earning an annual income of $55,000 and
$95,000.
The price rise ranges from 31 to 54 per cent. The price rise is an uneconomic tax on education, and
would be expected to cause a significant reduction in future enrolments in postgraduate study.
Table 3: Price rises for typical postgraduate courses
Course Cost per
annum
$5,000
Income
$55,000 per
annum
31%
Income
$95,000 per annum
38%
$10,000
41%
50%
$15,000
45%
54%
The $2,000 cap will cause a large reduction in postgraduate study
Universities Australia has surveyed its members on the potential decrease in enrolments in
postgraduate education if the $2,000 cap is introduced. They estimate a decline of between 13 and
31 per cent depending on the course and the institution:

A group of universities has estimated postgraduate student numbers could decline by up to 30
per cent.

One university which surveyed its students estimated 31 per cent would discontinue study if
the $2,000 cap was introduced.

Several universities expect postgraduate enrolments to fall by 20 to 25 per cent.

Some universities expected total postgraduate enrolments to fall by about 13 to 14 per cent.
The $2,000 cap will result in a reduction in future postgraduate
productivity
Using the above data and other inputs, Universities Australia has built a model to estimate the total
decrease in future postgraduate enrolments and completions if the $2,000 cap is introduced. The
model then estimates the long run lower production per annum from a less skilled workforce. Some
key inputs in the model include:

In 2013, there are estimated to be about 98,000 fee paying postgraduate students studying
part time. The decrease in new enrolments for this group would be expected to be significant
– given typical price rises for their courses of between 30 and 54 per cent as per Table 3
above. We have conservatively set the drop off rate for new enrolments at 20 per cent.
Submission to the Treasury Discussion Paper: Reform to deductions for education expenses
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
About 31,000 postgraduate students are fee paying and studying full time, where drop off
rates could be expected to be lower.

Students who have completed postgraduate education, in present value terms, on average
produce $270,000 more over their lifetime versus students who graduate with a bachelor
degree.11
The key results from the model are shown in Table 4, which estimates the loss of postgraduate
completions and productivity per annum from a lower skilled workforce, assuming the $2,000 cap has
been in place for several years. The model therefore provides a long run estimate of the negative
effects of the policy change in 2013 dollar terms.
Table 4: Long run loss of postgraduate productivity from the $2,000 cap
Model results
Decrease in post graduate
completions per annum
(2013)
Loss of future production per
non completion
Per annum loss to the
economy
6,300
$221,000
-$1.4b
The model produces the following key results:
11

Postgraduate completions will decrease by about 6,300 students per year in 2013. The
decrease in completions off this base would be expected to grow by about 3 to 4 per cent
per annum. 12 The loss of future production will experience a commensurate increase. The
6,300 students represent about 8 per cent of total domestic postgraduate completions, and
14 per cent of fee paying postgraduate students, so it is likely to be a conservative estimate of
the expected decrease in completions.

There is an estimated loss in future production, in present value terms, of $221,000
per person13 for every student who decides not to undertake and complete
postgraduate study.

The cap causes, each year, a loss of $1.4 billion of future production (6,300 X $221000). The
annual loss would be expected to grow by 4.5 to 6 per cent per annum in real terms, in line
with the progressively larger decrease in postgraduate completions over time caused by the
cap, and the per annum loss of productivity growth per postgraduate.14
See AMP.NATSEM ―Smart Australians‖ October 2012, especially at pages 28 to 30.
12
This estimate is based on the policy each year deterring a larger number of potential students from undertaking
postgraduate study, with future growth in postgraduate completions likely to be within a 3 to 4 per cent range absent the
policy change.
13
The average decrease in production per loss of a postgraduate completion is about $276,000 (in 2013 dollar terms),
AMP.NATSEM at page 30. The production function for post graduates would be subject to diminishing returns, so we
have conservatively adjusted down the average estimate by 20 per cent to account for diminishing returns and other
factors.
14
We estimate the loss of postgraduate completions from the $2,000 cap will grow by 3 to 4 per cent per annum.
Postgraduate productivity would be expected to grow at about 1.5 to 2 per cent per annum. So the year-on-year change
Submission to the Treasury Discussion Paper: Reform to deductions for education expenses
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The model provides a conservative estimate of negative effects
The model produces a conservative estimate of the total losses from the decline in postgraduate
education in Australia because it only includes direct first-round effects from the policy change. It
should be noted there are other negative implications, such as:

the disincentive for universities to invest in high quality postgraduate education and the
possible closure of some postgraduate courses, and loss of economies of scale and efficiencies
with others;

the difficulty for universities in introducing new postgraduate courses in new fields, especially
those that attract students with lower incomes;

a negative impact on Australia’s international reputation for high quality postgraduate
programmes and concomitant decrease in international student enrolments; and

reduced knowledge and skills transfer and diffusion through society.
The cap will cause a large decrease in future production
We have used our model to also provide an estimate for the economy-wide production losses, and
losses of long-term tax revenue from the $2,000 cap, given the following data:


the ATO statistics show 172,600 people claimed above $2,000 in education expense tax
deductions in Financial Year 2011;
we estimate students undertaking postgraduate education may make up between 40 to 55
per cent of the population claiming over $2,000. Hence the loss of postgraduate future
production may represent almost 50 per cent of the total lost production from the $2,000
cap.
Table 5: Long run loss of productivity and tax revenue from $2,000 cap
Economy wide model results
Loss of future production from a less
skilled workforce
-$2.8 billion
Loss of tax revenue from reduced
income tax take
-$1.07 billion
Extra tax revenue from double taxation
of education related income
$231 million
Net loss of tax revenue per annum
-$841 million
in lost productivity per annum equals the growth in lost postgraduates each year multiplied by the expected growth in
post graduate productivity per annum, or (3 to 4 per cent) X (1.5 to 2 per cent).
Submission to the Treasury Discussion Paper: Reform to deductions for education expenses
11
Table 5 demonstrates the following key points:

Every year the loss of future output that results from a less educated workforce is $2.8 billion.

This decrease in future production and tax revenue, partially offset by very high tax rates or
double taxation of education related income, results in a net loss of tax revenue in the order
of $841 million per annum.17
This equates to a long run decline in productivity growth of least a 0.2 per cent each
year15 – a consequence that is inconsistent with the Government’s goal to lift
productivity growth by at least 2 per cent per annum.16
The modelling results confirm that everyone, including Government, will be worse off under
the $2,000 cap.
The long-term impacts need to be modelled
Treasury figures in the 2014 Budget papers suggest the $2,000 cap will increase tax receipts by $250
million in financial year 2016 and $270 million in financial year 2017.18
No analysis is provided on the long term impact on the budget.
A proper long run analysis would:

estimate the decrease in people undertaking self-education caused by the $2,000 cap;

estimate, in present value terms, the loss of future production and income from the decrease
in skills;

estimate, in present value terms, the reduction in tax revenue caused by a decline in income;
and

incorporate the small increase in tax receipts from the double taxation of education related
income.
Using any reasonable or plausible assumptions, it can be expected that any proper analysis would
show a long-term decrease in tax receipts and a deterioration in the budget balance caused by the
double taxation of, and high effective marginal tax rates on, education derived income.
15
Australia’s GDP is estimated at $1520 billion in Financial Year 2013, see Treasury Budget paper no 1 2013-14. Taking
$2.8 from this number causes a 0.2 per cent decline in productivity growth.
16
Prime Minister Kevin Rudd in his address to the National Press Club on 11 July said: ―Average labour productivity
growth, which had risen to 2.1 per cent per annum during the 1990s, had fallen to 1.4 per cent in the decade just past,
although it has risen to 1.6 per cent over the year to March.
The challenge for the Australian Government is to accelerate a new national competitiveness agenda that boosts our long
term productivity growth. We need to aim for a productivity number with a ―2‖ in front of it.‖
17
This figure is derived using Treasury’s estimate in Fy 15 the $2,000 cap will collect an extra $250m of revenue. See
Budget paper No 1 2013-14 at page 5 - 20.
18
See Budget paper No 1 at page 5 – 20. We also note it is near impossible to produce an 8 per cent increase in tax
receipts from Fy 16 to Fy 17 under this policy unless an unrealistically low drop off rate is assumed for self-education in
response to 30 to 50 per cent price rises. Hence Treasury has not correctly modelled the policy in producing the Fy 14
Budget forecasts – by essentially ignoring the decrease education and lower resulting income in Fy 17.
Submission to the Treasury Discussion Paper: Reform to deductions for education expenses
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Government modelling suggests a $6 billion per annum loss
The most relevant and up-to-date Government modelling of the effects of changes in public
investment in tertiary education has been produced by the Australian Workforce and Productivity
Agency (AWPA) in March 2013: ―Future Focus, 2013 National Workforce Development Strategy‖.
This independent government modelling suggests the $2,000 cap would result in a $6 billion per
annum decrease in output and a $1.5 billion decrease in tax receipts.
In its report, AWPA called for a 0.1 per cent increase in Government investment in tertiary education
beyond current Treasury projections, to ―sustain Australia’s economic growth and meet industry
demand for qualifications at between 3 and 3.9 per cent per annum.‖19
AWPA found the increased investment, which would amount to an extra $2.1 billion per annum by
2025, would grow the economy in the long term by $54 billion per annum, and grow tax receipts by
$16 billion per annum on average.20 It also concluded that each extra dollar invested in tertiary
education grows the economy long-term by $26, and tax receipts by $8.
The AWPA model finds that increased government investment in tertiary education
produces compounding benefits to society.
The $2,000 cap will result in precisely the opposite of what AWPA has concluded, that is, a decrease
in Government investment in tertiary education by about $231million per annum (in 2013 dollar
terms).
Table 5: Decrease in output from the $2,000 cap, AWPA model*
Modelling results
Lower Government investment per
annum
-$231 million
Decrease in long term GDP per annum
-$5.98 billion
Decrease in long term net tax receipts
per annum
-$1.53 billion
* Universities
Australia estimate
Table 5 shows the long term impact of the decreased investment in tertiary education caused by the
$2,000 cap, using the AWPA model. GDP will decline by $6 billion per annum and tax revenue by
$1.5 billion per annum in real terms.
The Government has recently announced an objective to lift national productivity to at least
2 per cent per annum. But the AWPA model suggests the $2,000 cap policy would strip
productivity growth by 0.4 per cent per annum.
The AWPA outcome suggests Universities Australia has adopted a more conservative approach.
The AWPA report also noted:
―Projected growth in industry demand for total qualifications held … is expected to be
strongest at higher qualification levels, including postgraduate, undergraduate and
diploma/advanced diploma. The rate of projected annual growth in industry demand for
19
See ―Future Focus, 2013 National Workforce Development Strategy‖ at page 16. (Hereafter Future Focus report).
20
See Future Focus Report Appendix 6 at pages 179 to 182.
Submission to the Treasury Discussion Paper: Reform to deductions for education expenses
13
postgraduate qualifications is between 3.9 per cent and 4.9 per cent in the three higher
growth scenarios, while for undergraduate qualifications it is between 3.3 per cent and 4.1 per
cent. For diplomas and advanced diplomas projected annual growth is between 3.3 per cent
and 3.7 per cent.‖21
Postgraduate completions have historically grown at a healthy 4.6 per cent per annum over the period
2001 to 2011.22 Our analysis suggests the $2,000 cap will retard growth in postgraduate enrolments
and completions, with the growth rate falling to zero over the 2014-18 period.
The cap will therefore lead to a significant shortfall in the skills and qualifications required to meet
future labour market needs. Postgraduate completions are estimated to fall to 14 per cent below
AWPA recommended levels by 2018, and 22 per cent below AWPA recommended levels by 2025.
The proposed policy change will particularly impact on the very area that AWPA considers to be in
need of most investment: postgraduate training.
The losses from the cap grow as a percentage of GDP
As discussed above, we would expect the loss of productivity from the $2,000 cap policy to grow at
about 4.5 per cent to 6 per cent per annum in real terms, caused by the retarding effects of the cap
on the more important, higher growth sectors of the economy where specialised skills are most
needed.
The economy in total would be expected to grow at about 3 to 4 per cent per annum in real terms,
absent the policy, and by about 0.4 percentage points less per annum with the policy. So over time,
the productivity losses from the cap will increase as a percentage of GDP. In 20 years’ time we would
expect the lost productivity growth from the cap to increase by about 48 per cent from 0.4 per cent
of GDP to 0.6 per cent of GDP. In other words, the reduction in national productivity as a
consequence of this measure will increase over time.
Treasury has not applied its wellbeing framework in analysing the
$2,000 cap
Treasury has developed a wellbeing framework to refer to when assessing proposed policy changes.23
The framework is used to promote Treasury’s mission statement which states its objective is ―…to
improve the wellbeing of the Australian people by providing sound and timely advice to Government,
based on objective and thorough analysis of options.‖
Contrary to the Treasury’s own stated commitment, there is no evidence in the discussion
paper that an objective and thorough analysis of the issues has been conducted.
The paper identifies the key principle that self-education expenses incurred in gaining or producing
assessable income should be deductible against assessable income.24 The paper goes on to state that
people may have historically claimed expenses providing private consumption benefits, such as
overseas holidays, under this expense deduction category.25 Hence a policy change is justified to
21
See Future Focus Report at page 11.
22
DIISRTE: Higher Education Data Statistics (UCube).
23
See ―Treasury’s Wellbeing Framework‖, by Stephanie Gorecki and James Kelly.
24
See the Treasury paper at page 1.
25
See the Treasury paper at paragraph 45 page 9 and page 14.
Submission to the Treasury Discussion Paper: Reform to deductions for education expenses
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prevent people enjoying private benefits at taxpayers’ expense. No evidence is provided to support
this contention nor is any attempt made to quantify the problem.
Furthermore, the paper does not seek to identify, consider or analyse options for dealing with the
alleged problem. The paper simply asserts a $2,000 cap will fix it, without discussing whether this
indirect policy addresses the alleged issue.26
Universities Australia strongly supports a targeted approach to addressing any abuse of the
system and contends that this can easily be achieved without reducing legitimate workrelated deductible expenses.
The discussion paper fails to canvass options for tightening or improving the enforcement of existing
tax law, or introducing specific allowance rates for certain types of claimable expenditures such as
accommodation and travel. Instead it has arrived at a purported solution without understanding or
even clearly articulating the problem.
Inconsistency with the principles of the Treasury wellbeing
framework
An analysis of the $2,000 cap shows it is profoundly inconsistent with at least 4 of the 5 sub-principles
under Treasury’s wellbeing framework:
Principle 1: The set of opportunities available to individuals: the $2,000 cap fundamentally reduces
the set of education opportunities available. As shown at Table 2, even where the benefits of
education exceed costs by 50 per cent, individuals face punitive effective marginal tax rates of
between 93 to 103 per cent in undertaking such education.27
Principle 2: The distribution of those opportunities across society: the $2,000 cap targets and
especially affects people from poorer and disadvantaged backgrounds. In particular:

87 per cent of people who make a claim for an education expense deduction have a taxable
income below $80,000:

many postgraduate students making an expense claim are likely to be in the early – middle
stages of their careers, and may not have had the opportunity to build any significant wealth;

women, including those returning to the workforce and wanting to further their career
prospects, are likely to be particularly disadvantaged. One university noted its female/male
26
The Treasury discussion paper suggests amending Fringe Benefits Tax (FBT) legislation so employer paid self-education
would be exempt from the cap. That is, the employer could pay the self-education costs for their employee and would
not be subject to FBT. However, the paper also states if the employee salary sacrifices for the provision of the selfeducation expense, the FBT exemption would not apply:

salary sacrifice versus employer provided self-education is an arbitrary distinction that would be very difficult to
administer in practice;
 the distinction between employer and employee funded self-education is arbitrary. Both should be tax deductible;
 the alleged problem, professionals claiming private consumption benefits as education expenses, if it exists to any
significant degree, is unlikely to be reduced or addressed by the proposed measures. Professionals can continue
to provide these benefits to themselves as an employee of a private practice company and no FBT will apply. Or
they will continue to claim the benefits under existing Awards or Enterprise Bargaining Agreements in place and
no FBT will apply;
 the exemption provided for employer paid self-education expenses unfairly discriminates against those who are
not employed by larger employers who are more likely to be able to afford to fund employee education
expenses.
27
A person earning $95,000 of income per annum, incurring $15,000 of education costs per annum, where the
benefit/cost ratio is 1.5, will face an effective marginal tax rate of 103 per cent under the $2,000 cap.
Submission to the Treasury Discussion Paper: Reform to deductions for education expenses
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ratio for postgraduate students has increased over time and now sits at 1.8:1. Women on
average earn 40 per cent less than men. Further education represents the opportunity for
women to overcome income inequality. For example, a female with a postgraduate
qualification earns more than the average person, and approximately 45 per cent more than a
female with a diploma.28

the proposal will also disproportionately affect people from rural and regional communities
who generally incur higher costs (including those associated with travel and accommodation)
than others in participating in professional development and post-graduate studies;

people on lower incomes will find it particularly difficult to continue education in the face of a
30 to 50 per cent effective hike in the cost of post-graduate study;

universities have typically identified Masters of Nursing courses, and Masters of Education
courses as being especially affected by the $2,000 cap (See Appendix 1 for more details).
Principle 3: The sustainability of those opportunities available over time. This principle concerns
maintaining the stock of physical and human capital. The $2,000 cap is a tax on education that will
significantly erode the base of human capital over time as fewer people undertake further education
and training. The policy produces compounding losses in human capital from the decreased diffusion
of knowledge from a better educated, more highly-skilled population.
Principle 5: The complexity of the choices facing individuals and the community. This principle
concerns the transparency of government, and the ability of individuals to make choices and trade-offs
in their own best interests. As discussed above, there has been no transparency in developing the
$2,000 cap policy: it has simply been announced without consultation or cost/benefit analysis and with
no consideration of alternatives for dealing with the alleged problem.
The $2,000 cap undermines individuals’ ability to make trade-offs matching their preferences, by
imposing 100 per cent or higher tax rates on those seeking welfare-enhancing education. It also
distorts choices and preferences away from professional development, training and education to other
less productive investment decisions.
28
See AMP.NATSEM report at pages 30 to 32. The expected lifetime income of a female with a postgraduate qualification
is $2.49 million, the expected lifetime income for a person on average is $2.3 million, and $1.7 million for a female with a
diploma.
Submission to the Treasury Discussion Paper: Reform to deductions for education expenses
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An alternative, revenue neutral, proposal
The Treasury discussion paper at Question 6 page 11 asks whether the $250 no-claim threshold for
claiming self-education expenses should be removed if the $2,000 cap is introduced.
It is the strong view of Universities Australia that the $250 no-claim threshold should be removed and
the $2,000 cap should not be implemented. The $250 no-claim threshold is a narrow, inefficient,
arbitrary and highly distorting tax base, applying to just 7 per cent of total work-related expense
claims. Universities Australia recommends that consideration be given to the following:
1. Replace the $250 no-claim threshold for education expenses with a $20 no-claim threshold
for all work related expense deductions. This would maintain the same net revenue as
currently collected by the $250 no-claim threshold for work related self-education expenses;
Or
2. Replace the $250 no claim threshold for education expenses with a $90 no claim threshold
for all work related expense deductions. This proposal would maintain the same net revenue
as estimated for the $2,000 cap over the short term.29
The $90 no-claim alternative is significantly better tax policy compared to the $2,000 cap proposal:

It is fair. It does not arbitrarily and uneconomically discriminate between education and other
work related expenses – avoiding treating other work expenses, without justification, more
favourably.

It broadens the tax base from 175,000 tax payers to about 8.6 million tax payers.

It has an effective rate of tax that is 98 per cent lower. The $90 no claim threshold collects on
average just $27 per tax payer per year,30 whereas the $2,000 cap on average collects $1,300
per annum from each person hit by the cap.

It is unlikely to change peoples’ behaviour, and therefore lowers the cost to the economy
from raising extra tax revenue by over 99 per cent. We estimate the costs of raising the extra
tax revenue under the $90 no claim alternative to be about $1 million to $2 million per
annum, whereas the $2,000 cap causes $2.8 to $6 billion per annum of lost production.31

It collects an increasing amount of tax revenue over the long term, whereas the $2,000 cap
has a negative effect on tax revenue over the long term.
29
The $90 no claim threshold will be a superior tax revenue collector over the longer term, because it will have a
minimalist, if any effect on economic growth –whereas the $2,000 cap decreases long run GDP by between $2.8 billion
and $6 billion per annum, and decreases long run net tax receipts by between $800 million to $1.5 b per annum.
30
The maximum cost per person under the $90 no claim threshold is $41.85 per annum, which only applies to people
earning over $180,000 per annum.
31
The effective rate of tax would be 98 per cent lower under our base broadening proposal. Welfare costs of raising tax
vary directly with the square of the tax rate. So a doubling of the tax rate produces an approximate quadrupling of the
welfare loss. See Harberger, Arnold C., ―1966, Efficiency effects of taxes on income from capital‖, in: Marian Krzyzaniak,
ed., Effects of corporation income tax (Wayne State University Press, Detroit), 107-117.
As a general principle, if new taxes are introduced, it can be shown that it is better to levy the tax on as broad a base as
possible, allowing a lower rate to collect the same amount of tax, and causing less distortion to decisions.
For example, a tax covering 2 per cent of a total base, set at a 50 per cent rate, causes investment distortions and welfare
losses to the economy that are 2,500 times greater than a tax set at 1 per cent covering the whole base which collects the
same amount of revenue.
Submission to the Treasury Discussion Paper: Reform to deductions for education expenses
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It is Universities Australia’s contention that option 2 is a more robust, defensible, fairer approach to
delivering a short term $500 million budget saving without creating a major disincentive to those
prepared to invest in their own education, or diminishing the capacity for the Government to realise
its desire to lift national productivity.
Submission to the Treasury Discussion Paper: Reform to deductions for education expenses
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Appendix 1: Some responses from universities and students
Surveys show a cap on education tax deductions would deter
students
Surveys by universities of actual and prospective postgraduate students suggest postgraduate
enrolments will significantly decline.

A survey conducted at a 2013 University Postgraduate Expo found 42 per cent of
respondents identified fees as the most significant barrier preventing them from commencing
postgraduate studies.

A university conducted a survey of domestic postgraduate coursework students. Thirty one
per cent of respondents indicated they would not continue with their studies if the $2,000 cap
was introduced. A further 25 per cent indicated uncertainty with regard to their ability and/or
willingness to continue study.

A survey at a university business school of close to 700 students highlighted that they
considered reducing fees as one of three major priorities for the School. The survey reinforces
the view that there is limited tolerance for cost increases.

A survey of MBA students by a university, with 139 responses, found approximately 77 per
cent of these students were either fully or partially self-funded.

A survey of postgraduate students studying a variety of courses including fire safety, adult
education, building surveying, information and communications technology found nearly five in
eight students are paying all or a substantial proportion of their postgraduate costs.
Science and mathematics teachers are especially hurt by the cap
Many teachers, especially in science and mathematics, undertake a Masters in Education to upgrade
their skills, allowing them to move from Primary to Secondary teaching, or to undertake more
specialist and higher skilled roles in the Primary system.
At one university, the teachers undertaking these courses are typically self-funded and study up to half
time. Annual tuition fees for these teacher-students are in excess of $6,000 for a typical half time
study load. A $2,000 cap on self-education expenses would be a significant disincentive for these
teacher-students as it:

has a substantial deterrent effect on the incentive for these teachers to enrol in the Masters
program, and therefore will negatively impact their future teaching and students;

will cause a significant decline in future enrolments in the course; and

negatively impacts on the teaching of Science, Technology, Engineering and Mathematics
(STEM). STEM skills lie at the core of Australia’s ability to innovate and develop economically
(West 2012).32
Skills shortages in mental health and counselling exacerbated by the
cap
A member university reported that postgraduate students studying psychology are typically working
within the profession and motivated by a desire to upgrade their skills and qualifications. These
32 West, M (2012) Stem education and the workplace, Office of the Chief Scientist, Occasional Paper Series, Issue 4
Submission to the Treasury Discussion Paper: Reform to deductions for education expenses
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students are usually self-funded and study on a half time basis. The average tuition fee for this course
is $8,700 per year. The $2,000 cap results in a significantly increased financial burden for the students
and a typical effective price increase of between 40 and 50 per cent.
The university expects a significant decrease in future enrolments if the cap is introduced. The
students doing these postgraduate psychology courses work in areas such as mental health and
counselling – areas already subject to skills shortages.
Workplace safety negatively impacted by the cap
The Graduate Diploma in Occupational Health and Safety at a university supports improving the
ability of organisations to provide a safe worksite. Individuals who enrol are often self-funded. The tax
deduction for self-education is a key factor in their decision. The tax deduction would result in savings
of $5,270 over the two years of this course for someone on a salary of $75,000 (representative for
people doing this course).
The $2,000 cap would reduce the tax deductibility to $1,360 for the course, a reduction of $3,910.
Given the characteristics of those studying the course, the increase in costs will significantly impact the
cost/benefit analysis conducted by potential students. A significant decline in future enrolments is
anticipated.
The cap does not fit the fees
One university discussed the difference between the $2,000 cap and their typical course fees for
postgraduate study. In their business school the average annual tuition fee for a student in the Masters
of Financial Analysis studying part time is $13,560, almost seven times the proposed $2,000 annual
cap.
The changes will also have a severe adverse impact on:

Engineering (average $4,900);

Built Environment (average $5,900);

Law (average $9,503); and

Medicine (average $4,365).
These figures are based on head count, not full time equivalents. These students are studying on
average 35 per cent of a full time load. Consequently, a full time student would on average pay
$17,085 per annum in fees.
The cap reduces professional up-skilling
A number of professions require formal education for membership to the profession and on-going
registration and accreditation. The requirements can involve a degree for entry, and/or an ongoing
requirement to continually improve and update skills.
Some examples of Continuous Professional Development (CPD) requirements are as follows:

Graduate Certificate in Palliative Care. The course allows nurses to upgrade their skills,
specialise to improve their career, and improve their ability to provide high-quality and
appropriate pain-relief for patients. Nursing is a relatively low-paid occupation. The fees to
undertake postgraduate study are thus a relatively greater burden. Fees in 2013 are $4,480.

Postgraduate Certificate in Education (International Baccalaureate). The course is used by
teachers to improve their ability to teach the International Baccalaureate to secondary school
students. Expertise in specific subjects improves the teacher’s career opportunities, and their
Submission to the Treasury Discussion Paper: Reform to deductions for education expenses
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ability to provide an internationally relevant, high quality education to students. Fees in 2013
are $8,800.

Master of Supply Chain Management. Professional engineers are required to keep their skills
up to date and relevant, such as by completing this type of course, to retain status as a
Chartered Member of Engineers Australia. Skilled engineers are essential to Australia’s ability
to innovate and use the latest technological developments. Fees in 2013 are $27,392 for the
full course.

Postgraduate Diploma of Legal Practice (also known as Professional Legal Training) is
required for admission to the Queensland Roll of Lawyers. Tuition only fees for full time on
campus study are $16,536 in 2013.

Master of Real Estate – required to be Certified Practising Valuer (Australian Property
Institute)

Master of Urban Planning – required to qualify for professional membership with the Planning
Institute of Australia.

Master of Architecture – required by the Architect’s Accreditation Council of Australia
(AACA) for professional registration with the Australian Institute of Architects.

Master of Project Management – required to qualify for professional membership with the
Australian Institute of Project Management (AIPM)

Master of Construction Practice – required to qualify for membership of the Australian
Institute of Quantity Surveyors.
Representative examples and quotes from students.
The following provides a set of examples and quotes from students on the practical effects of the
$2,000 cap:
A university surveyed its postgraduate health science students. The following is a typical example
response provided by one nurse. She works as a registered nurse in a public hospital and studies part
time. She is undertaking her studies to specialise and so advance her career:
―Given my current income, the proposed cap will make postgraduate study too expensive, so I will
discontinue the course. Alternatives to university postgraduate study do not provide me with the
same level of in depth knowledge. Not being able to pursue this study will negatively impact my
career, and will also lead to less skilled specialist nurses in the health system.‖
A postgraduate education student has around 12 years teaching experience. She aspires to be a
principal and educational leader and proposed to study the Master of Educational Leadership part
time to improve her knowledge and help her gain a leadership position in education The fees for this
course are $12,800 per year. She states:
―If the $2,000 cap is introduced I will either not enrol, or will have to significantly slow down the pace
of study so that it remains affordable. This change lessens my ability to progress my career, decreases
the skills available to teach young people, and will reduce the leadership pool in schools.‖
Other representative quotes of concern from students planning to give up study because of the cap:
―This change will discourage people to seek further education as it will significantly increase the cost. I
will have finished my Masters by the time this comes in, but probably would not have completed a
Masters with the $2k cap. Given a completion rate of 2 units per trimester, it would cost around $21k
per year, and with only $2k tax deduction this would have a massive impact on affordability.‖
―For me, it will prevent me from claiming a lot of my tax deduction which helps me to afford the
course. I have a family and am the primary earner and the tax deduction greatly helps. I think it will
Submission to the Treasury Discussion Paper: Reform to deductions for education expenses
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stop people from doing the Masters as it is a significant investment and very expensive without the
tax deduction.‖
―It is going to impact on my incentive to finish my studies in Australia – I might as well transfer to the
US and finish off my studies there. This is going to impact on the development of a knowledge
economy in Australia. We might as well go get a mining job and skill up on dirt digging abilities. This
change to the tax laws is short-sighted and is just a reflection of this Government’s inability to govern
for all Australians over the long term.‖
―If this cap relates to university fees it is a real concern for me. I am a single mum working part-time
and studying part-time. I would not be able to afford to study. I really hope not!‖
―The cap will seriously affect my study program. I might be forced to consider dropping the course
entirely. I might not have enough money to pay for the course without the tax deduction program.
The government is not realistic about the current uni fee. The $2,000 cap is not even sufficient to pay
for one unit, which costs me $3800. There are also other costs associated with the study such as
books. The government should assist hard working people like me. The completion of the course
enables me to advance to a higher paying job which returns higher income tax. The government
should encourage its citizens to continuously develop their skills set and knowledge.‖
―This would mean that I would be unable to complete my Master’s degree, (that simple) wasting 3
years of part time study.‖
―If I was unable to claim back the full tax amount, I would be unable to continue studying as I would
not have the funds. I could drop down to one unit a trimester however; I need this valuable
knowledge to help me advance my career.‖
―These changes are significant and will cost me at least $3,500. I find it strange that the Government
sees merit in this decision. Through personal development I hope to secure better remuneration,
adding to the tax I pay.‖
―This change will deter a lot of my staff who self-fund their education. Universities will struggle and I
think it is a disastrous decision. Australia will be worse off; if the economy falters education is key. This
decision will mean many will not be in a position to fund education.‖
―The cap will mean that it will take a lot longer to do such courses and the problem is that we have a
maximum of 5 years. They are effectively putting such courses out of reach of most unless your
employers are going to sponsor these courses, and the truth is that fewer and fewer employers are
willing to fund these courses.‖
―With a $2,000 cap, I would not consider studying a Masters.‖
―The proposed changes are an outrage. The country needs further incentive to study not less. The
decision to study is often short term pain/long term gain for both the person and the community. As
an undergraduate, you forego earnings and the associated opportunities in order to study. Later, in
postgraduate study, any incentive to study is a good one. We should attempt to attract and retain the
best and brightest. This means high costs although very high benefits. To avoid high education costs
being a deterrent, any financial benefit such as a tax deduction, is beneficial. To increase tax revenue
in the short term by making this change, will have adverse untold long term effects on a country that
seems to be tilting heavily towards a future of unskilled versus skilled local industry.‖
―I know that this would change my decision to complete a Masters. I am fully self-funded and $2,000
doesn't even cover one unit. The cost to improve myself under the potential changes would far
outweigh the benefits at this stage in my life - 37, paying a mortgage, young children.‖
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