In one sense, the High Court judgment in FCT v Carter [2022] HCA 10 (Carter) will come as welcome relief for tax advisors. That is, after dealing with the Australian Taxation Office’s (ATO) view of the ‘lore’ in the form of practical compliance guidelines, Carter turns minds back to the ‘law.’ Unfortunately, the law in Carter can result in unpleasant tax outcomes for certain trust beneficiaries.