Published on 23 Sep 09
by VICTORIAN DIVISION, THE TAX INSTITUTE
This presentation covers:
- unit trusts versus fixed trusts, the nature of "fixed entitlements", and the relevance of these concepts for trust losses, franking credits & superannuation fund investors
- what do hybrid trusts look like, how effective & useful are they, and what are the risks associated with them?
- when might a unit trust be preferred over a partnership of discretionary trusts?
- is a unit trust subject to perpetuity period rules?
- characterisation of unpaid present entitlements
- impact on unit trusts of proposed changes to Division 7A
- Div 152 structuring - the impact of the revised definition of "affiliate"
- Div 152 structuring - the problem with different classes of units
- hybrid trusts - interest deductibility on borrowings to acquire units following TD 2009/7
- fixed trust cloning.
Jeffrey is a Partner at Thomson Geer, where he advises on a wide range of taxation, structuring and superannuation issues with a focus on privately-held businesses and high wealth family groups. His is accredited by the Law Institute of Victoria as a taxation specialist. He has held a variety of committee roles with The Tax Institute and is presently a member of the Victorian State Council. Jeffrey is the author of numerous tax articles published in professional journals, and a regular presenter at The Tax Institute's seminars.
- Current at
06 June 2016