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Use and abuse of corporate beneficiaries case study and solutions paper


This paper looks at a range of issues related to the use of corporate beneficiaries – past, present and future. Practical case studies will work through some of the issues that have arisen, and will continue to arise, due to the popularity of corporate beneficiaries and the fact that many taxpayers still use them even in light of the many changes.

Issues to be explored includes:

  • streaming franked dividends to corporate beneficiaries
  • continuing appointment of trust net income to companies
  • the ongoing impact of quarantined UPEs
  • sub-trusts:
    • timing of the investment agreement
    • when are the payments under the investment agreement required to be accounted for and paid?
    • what is the strategy at the end of 7 years or 10 years to pay the sub-trust?
  • the implications of creating a Division 7A loan between the company and the trust, including the timing of Division 7A application
  • interest deductibility for both sub-trust returns or the interest component of Division 7A 109N repayments
  • using the corporate beneficiary as the “balance beneficiary” in the trustee resolution prepared at 30 June
  • application of 109XI and other provisions within Division 7A
  • refreshing strategies.

Author profile:

Author Photo - Ian SNOOK
Current at 04 May 2011 Click here to expand/collapse more articles by Ian SNOOK.


This was presented at 2012 South Australian Tax Intensive .

Get a 20% discount when you buy all the items from this event.

Individual sessions

Maximising the benefits offered by SMSF structures case study and solutions

Author(s):  Stephen HEATH

Materials from this session:

Use and abuse of corporate beneficiaries case study and solutions

Author(s):  Ian SNOOK

Materials from this session:

Real property transactions: Opportunities and pitfalls case study and solutions

Author(s):  Michael Chrisohoou

Materials from this session:

Further details about this event:


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