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Non-resident beneficiaries - income tax paper

Member Price: $57.00
Non Member Price: $75.00

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Unless expressly stated, opinions are not that of The Tax Institute, which accepts no responsibility for the accuracy of any of the information contained within it.

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:

  • non-residency
  • income entitlements (including capital gains, streaming withholding tax and other trustee obligations)
  • capital entitlements
  • thin capitalisation
  • the implications of generational change.

Author profile

Terry Murphy QC, CTA
Terry has focused 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 and was a Past President of the Tax Bar Association. Terry 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 30 August 2021
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This was presented at 21st National Convention: Beyond the Sea .

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