Private Wealth and Trust Disputes Notes

Australian Taxation Office targets investors seeking to adopt capital gains tax treatment on sale of shares

TAXING PRIVATE TRUSTS IN AUSTRALIA - A MOVING TARGET

The Australian revenue authorities have been very active recently issuing judgments, making pronouncements and intensifying enforcement activity, all …

Circular trust resolutions – family trusts to be taxed at 47% by Australian Government

Following on from the Australian Government’s announcement in the 2018-19 Budget, an Exposure Draft entitled Treasury Laws Amendment (Measures for a …

FATCA: First-ever conviction signals increased enforcement risk

The former CEO of Saint Vincent-based Loyal Bank pleaded guilty and was convicted on 11 September of conspiring to defraud the United States by failing …

Australian tax law bites trust law on franking credits

The High Court of Australia has restored sanity in a long running saga in which a trustee purported to separate franking credits from the underlying …

Australian Board of Taxation reviews residency test for individuals

On 9 July 2018, the Board of Taxation (the "Board") released its self-initiated report ‘Review of the Income Tax Residency Rules for Individuals’ (the …

Personal representative liable for inheritance tax on fully distributed estate

  The First-tier Tax Tribunal ("FTT") has provided a valuable reminder in the case of Harris v HMRC [2018] UKFTT 204 that, with limited …