This paper focusses on tax planning for individuals who migrate from the United Kingdom or New Zealand to Australia, or from Australia to either of those countries. It considers the tax issues that arise where the client controls trusts established in the country of entry or exit:
- determining whether a trust is an Australian resident
- Australian tax consequences of foreign trusts earning income from 'tax haven' countries
- advising a NZ or UK resident client changing residence to Australia of tax consequences for controlled foreign trusts
- advising a client of the Australian tax consequences for a controlled foreign trust if client becomes a non-resident.