Taxing times for foreign resident beneficiaries

Neil Lamb & Steve Plant discuss two draft taxation determinations which may disincentivise foreign resident investors.

The Australian Taxation Office (ATO) has released two draft taxation determinations which may have the effect of bringing non-residents into the Australian tax net, notwithstanding that there is no gain sourced in Australia. This would seem to act as a disincentive to foreign resident investors and may provoke restructuring of current holdings to preserve the tax profile of current investments. There may also be wider consequences for managed investment trusts that do not benefit from deemed ...

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Authors: Neil Lamb, Steve Plant

Published Date: 01 October 2019