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, QC, CTA, is a Barrister at Chancery Chambers. He practises at the Victorian Bar in revenue law, trust and superannuation law, corporations law and commercial law, and has appeared for both taxpayers and the Commissioner in the High, Federal and Supreme Courts. Terry is a member of the Taxation Committee of the Business Section of the Law Council of Australia, a member of the Melbourne Law Masters Tax Advisory Board at the University of Melbourne (where he lectures in the LLM program), the Bar's representative on the School of Law Program Advisory Committee of Victoria University and a frequent presenter at state and national conferences of The Tax Institute and other professional bodies. Terry was appointed Special Counsel to the ATO from 2008 until 2010.
- Current at
12 January 2017