Sub Trusts Part 2 1. I have had some interesting discussions regarding the article Why I Hate Your Sub-Trust, and wanted to set out and respond to some comments that have been made. In particular I would like to acknowledge the thoughts of Grahame Young of Francis...
On 9th November 2023 the ATO has released web guidance in relation to decentralised finance and wrapping crypto transactions. I presented the below example over a year ago at seminars for The Tax Institute, private clients, and in submissions to Treasury. The ATO has...
10 Things I Hate About Your R&D Claim The Australian Government offers a generous incentive for Australian companies to conduct R&D activities in Australia. The ATO can refund up to 45% of your R&D expenditure. Such an attractive proposition leads many to...
There is a certain type of sub-trust over income that many trust deeds purport to create, and which the Federal Commissioner purports to allow. This is where a trust is established over the income distributed from another trust. This is problematic for the reasons...
Why We Should Abolish The Income – Capital Distinction Much of the present tax system was designed in an era of physical industry and service and is not well suited to the modern intellectual property-based environment. The past 20 years of “tax reform” has mostly...
Bill Gates has suggested that in response to robots taking the jobs of humans, there should be a robot tax. As a tax lawyer who builds artificial intelligence (and known as the Taxinator), of course I am going to have some comments. His line of reasoning is that a...
