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Article
Treasury Releases Consultation Paper On 30% Minimum Tax For Discretionary Trusts, With Major Questions Still To Answer
The Australian Treasury has released a consultation paper on implementing a 30% minimum tax on discretionary trusts, announced in the 2026-27 Budget. This comprehensive analysis examines the proposed framework's implications, including CGT rollover relief for restructuring, treatment of corporate beneficiaries facing effective double taxation, and the complex interplay between federal tax law, trust law, and state transfer duty obligations.
Australia Tax
PA
Piper Alderman
Article
Thinking Of Moving Overseas? Key Australian Tax Residency Issues To Consider
Recent Federal Budget tax reforms have prompted many Australians to consider relocating overseas, but the complexities of tax residency often lead to unintended consequences. Understanding the distinction between tax residency and immigration residency, along with dual-tax residency implications and recent tribunal determinations, is crucial for anyone planning an international move. Key considerations include how Australia determines tax residency, the role of Double Tax Agreements, and recent case law tha
Australia Tax
CG
Coleman Greig Lawyers
Article
Bendel – The High Court Has Spoken, But Is This The Final Word On Taxation On Unpaid Present Entitlements?
The High Court of Australia has delivered its landmark judgment on whether unpaid present entitlements from a trust to a corporate beneficiary constitute a loan under Division 7A of the Income Tax Assessment Act 1936. This decision resolves a critical question that has significant implications for how trusts structure distributions to corporate beneficiaries and whether such arrangements trigger deemed dividend treatment under Australia's tax integrity provisions.
Australia Tax
PA
Piper Alderman
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Tax Treaties

Article
Thinking Of Moving Overseas? Key Australian Tax Residency Issues To Consider
Recent Federal Budget tax reforms have prompted many Australians to consider relocating overseas, but the complexities of tax residency often lead to unintended consequences. Understanding the distinction between tax residency and immigration residency, along with dual-tax residency implications and recent tribunal determinations, is crucial for anyone planning an international move. Key considerations include how Australia determines tax residency, the role of Double Tax Agreements, and recent case law tha
Australia Tax
CG
Coleman Greig Lawyers
Article
ATO Releases Decision Impact Statement On Bendel – The Wait Is Over, But Was It Worth The Wait
The Australian Taxation Office has released its Decision Impact Statement following the High Court's landmark Bendel judgment on unpaid present entitlements and Division 7A. While some taxpayers who maintained passive arrangements may find relief, significant questions remain about the application of anti-avoidance provisions and the Commissioner's discretionary powers. The statement signals important changes to longstanding ATO guidance and raises critical considerations for trust and corporate beneficiary
Australia Tax
PA
Piper Alderman
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Inheritance Tax

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Income Tax

Article
Treasury Releases Consultation Paper On 30% Minimum Tax For Discretionary Trusts, With Major Questions Still To Answer
The Australian Treasury has released a consultation paper on implementing a 30% minimum tax on discretionary trusts, announced in the 2026-27 Budget. This comprehensive analysis examines the proposed framework's implications, including CGT rollover relief for restructuring, treatment of corporate beneficiaries facing effective double taxation, and the complex interplay between federal tax law, trust law, and state transfer duty obligations.
Australia Tax
PA
Piper Alderman
Article
Thinking Of Moving Overseas? Key Australian Tax Residency Issues To Consider
Recent Federal Budget tax reforms have prompted many Australians to consider relocating overseas, but the complexities of tax residency often lead to unintended consequences. Understanding the distinction between tax residency and immigration residency, along with dual-tax residency implications and recent tribunal determinations, is crucial for anyone planning an international move. Key considerations include how Australia determines tax residency, the role of Double Tax Agreements, and recent case law tha
Australia Tax
CG
Coleman Greig Lawyers
Video
It Depends – What Are The Proposed Changes To Negative Gearing Announced In The 2026 Federal Budget? (Video)
The Australian Federal Government's 2026 Budget proposes significant changes to negative gearing rules for residential property investors, set to take effect from July 2027. Under the proposed legislation, negative gearing will only apply to new residential dwellings, while existing properties purchased before May 12, 2026, will be grandfathered under current ownership.
Australia Tax
CG
Cooper Grace Ward
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Transfer Pricing

Article
Don’t Let Australia’s R&D Tax Incentive Trigger Unintended US International Tax Cost Sharing Issues
US technology, pharma, and life science companies establishing Australian subsidiaries to access R&D tax incentives face complex international tax challenges. When intercompany agreements are drafted without proper coordination between US transfer pricing rules and Australian R&D Tax Incentive requirements, companies risk significant IRS exposure including platform contribution payment obligations, cost reallocations, and penalties that can exceed the intended tax benefits.
Australia Tax
W
WilmerHale
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Latest Videos

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