This presentation covers:
- Division 6B - dinosaurs still have big teeth
- Division 6C - the industry has outgrown it, are we at risk of falling behind world’s best practice?
- stapling - how does it work and why does the ATO have issues with it?
- distributions of income and capital - yield is king but tax deferred isn’t far behind
- going offshore - 6C, DTAs and other obstacles to a simple commercial structure
- trust taxation and the Division 6B and Division 6C alternatives
- excepted trusts and their exclusively ‘eligible investment business’
- stapling structures
- are interests in stapled entities ‘listed’? - Implications for tax treatment of stapling
- interaction with capital streaming.