Published on 06 Apr 06
by NATIONAL EVENTS, TAXATION INSTITUTE OF AUSTRALIA
What are the implications of a non-resident becoming entitled to income, capital or control of a closely held trust especially in the context of generational change? This paper includes:
- income entitlements (including capital gains, streaming withholding tax and other trustee obligations)
- capital entitlements
- thin capitalisation
- the implications of generational change.
Terry Murphy QC, CTA, has focussed on advising and appearing for taxpayer and revenue authorities in the Federal Court and High Court and in alternative dispute resolution for over 30 years. He was appointed to be the Special Counsel to the Australian Taxation Office from 2008 to 2010, is a member of Taxation Subcommittee of the Law Council, Chair of the Tax Group Advisory Board, and a Senior Fellow of the University of Melbourne Law School.
- Current at
03 August 2017