Our international tax series considers tax issues for non-resident beneficiaries of Australian trusts and Australian beneficiaries of non-resident trusts. The series considers the tax residency rules and income tax and capital gains tax (CGT) consequences for beneficiaries and trusts alike.

Treasury has released exposure draft Taxation Administration (Private Ancillary Fund) Guidelines 2019 (2019 Guidelines), in anticipation of the sunsetting of Private Ancillary Fund Guidelines 2009, which is scheduled to occur on 1 October 2019.  

When involved in a dispute with the Australian Taxation Office (ATO), the possibility of resolving that dispute by way of settlement should always be carefully considered including what approach should be taken in negotiating with the ATO to get the best outcome for taxpayers.