Managed investment trusts
Source: The Tax Specialist Journal Article
Published Date: 1 Apr 2012
The purpose of this article is to discuss the key issues arising out of the current review of the managed investment trust (MIT) taxation regime, the legislative response to which has been deferred. The article examines the Board of Taxation’s report, the government’s response, and the Treasury discussion paper. The article then considers contentious issues in the MIT review, including the need for a clear definition of rights, the treatment of “unders” and “overs”, the arm’s length rule, and the retention of the tax character of amounts flowing through a trust.
The article deals with MIT issues not yet covered in consultation, including attribution methodology, cost base adjustments, interaction with non-resident withholding tax rules, some interim changes to the taxation of trust income, and the concept of the fixed trust. The article concludes with a discussion of current proposals for the reform of the trusts rules in Div 6 of the Income Tax Assessment Act 1936 (Cth).
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Details
- Published By: Dudley Heywood, Andrew Mills CTA-Life
- Published On:1 Apr 2012
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