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Profit accumulation tax traps paper

Member Price: $57.00
Non Member Price: $75.00

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Published on 08 Nov 12 by NATIONAL DIVISION, THE TAX INSTITUTE

By far, one of the greatest challenges facing SME businesses that operate through trust structures is avoiding the penal tax outcomes that are possible when operations are financed through profits that have been taxed at the corporate tax rate.

This paper examines some of the methods that have been developed to work with the new paradigm imposed by the Commissioner’s UPE ruling, including:

  • developing practices with corporate beneficiaries
  • lessons learned from completion of 2011 accounts
  • implications from the February 2012 Montgomery Wools Case
  • risks and opportunities through licensing goodwill.

Author profile

Chris Wookey CTA-Life
Photo of author, Chris WOOKEY Chris Wookey, CTA (Life) operates his own specialist tax consulting practice after previously having been a principal in the tax consulting division of Deloitte Private in Melbourne. A finalist in The Tax Institute’s Tax Adviser of the Year Awards for 2020 and 2022 and made a life member of The Tax Institute in September 2023, he has over 30 years’ experience in the chartered accounting profession and is a member of The Tax Institute’s national SME Technical Committee and had been its representative on the ATO’s Private Groups Stewardship Group from 2021 to 2022. Chris was also a member of the Board of Taxation’s Reference Group for its Review of Small Business Tax Concessions. His experience, centred on issues encountered by private groups, includes providing input to Treasury in relation to the proposed targeted amendments to the Div 7A integrity rules and participating in confidential consultations with the ATO in relation to the 2022 and 2023 developments in relation to section 100A. - Current at 29 January 2026
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This was presented at 20th National Tax Intensive Retreat: Expanding the Family Business .

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

Individual sessions

Structuring and restructuring the expanding business

Author(s):  Gil LEVY

Materials from this session:

Issues regarding SMEs and group structures

Author(s):  Paul LYON

Materials from this session:

Profit accumulation tax traps

Author(s):  Chris WOOKEY

Materials from this session:

You can't take it with you

Author(s):  Suzanne McKENZIE

Materials from this session:

Workshop 1 questions and answers

Author(s):  Jo-anne HOTSTON

Materials from this session:

Rewarding and retaining key personnel of the growing businesss

Author(s):  Meagan O'CONNOR,  Rob JERAMIAH

Materials from this session:

Workshop 2 questions and answers

Author(s):  David MARSCHKE

Materials from this session:

Workshop 3 questions and answers

Author(s):  Michelle HARTMAN,  Kevin J MUNRO

Materials from this session:

Intellectual property, goodwill and taxation

Author(s):  Domenic CARBONE

Materials from this session:

Further details about this event:

 

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