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Profit accumulation tax traps presentation
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 presentation 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
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
This was presented at 20th National Tax Intensive Retreat: Expanding the Family Business .
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Individual sessions
Structuring and restructuring the expanding business
Author(s): Gil LEVYMaterials from this session:
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Issues regarding SMEs and group structures
Author(s): Paul LYONMaterials from this session:
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Profit accumulation tax traps
Author(s): Chris WOOKEYMaterials from this session:
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You can't take it with you
Author(s): Suzanne McKENZIEMaterials from this session:
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Workshop 1 questions and answers
Author(s): Jo-anne HOTSTONMaterials from this session:
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Rewarding and retaining key personnel of the growing businesss
Author(s): Meagan O'CONNOR, Rob JERAMIAHMaterials from this session:
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Workshop 2 questions and answers
Author(s): David MARSCHKEMaterials from this session:
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Workshop 3 questions and answers
Author(s): Michelle HARTMAN, Kevin J MUNROMaterials from this session:
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Intellectual property, goodwill and taxation
Author(s): Domenic CARBONEMaterials from this session:
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