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  1. JIT

    Another Blow to Hybrids

    Hi nonrecourse, Thanks for that contribution. As you said, it's much easier to understand with pictures. You seem like you have a pretty strong understanding of the accounting involved in this structure. I'll need to re-read this post again before I fully grasp what you were trying...
  2. JIT

    Another Blow to Hybrids

    Thanks for sharing non-recourse. I don't quite follow though, do you negative gear with units used to purchase property in a HDT? GSJ
  3. JIT

    Another Blow to Hybrids

    With all this discussion about HDT's, I really wonder about the PIT, and how confident its creators are about its legitimacy as an investment structure and what they are doing to make sure it is all OK with the ATO??? I recall something from previous discussions about diverting income to...
  4. JIT

    Another Blow to Hybrids

    Thanks for your reply Julia. I think the counter-argument against PBR 66298 is that the trust deed in this case was not appropriately worded, which I think Dale had suggested earlier. Are these the only two PBR's on HDT's??? GSJ
  5. JIT

    Another Blow to Hybrids

    Thanks James, I think I follow it. I think it basically suggests that negative gearing with HDT's is OK. However, I don't think it addresses the Part IVa 'tax benefit' issue that may arise out of redeeming all units and then selling the property, and streaming subsequent capital gains to...
  6. JIT

    Another Blow to Hybrids

    Hi Dale, I didn't realise that. Can't recall if this ruling was discussed on the forum or not, but, are you able to post a link to it? Thanks, GSJ
  7. JIT

    Another Blow to Hybrids

    This may be a stupid question, but, why wouldn't someone who is promoting HDT's for negative gearing IP's (amongst other things) have gotten a favourable private binding ruling from the ATO for a client using one of their HDT deeds, at the very beginning, BEFORE selling it to others (doing a...
  8. JIT

    Another Blow to Hybrids

    Maybe if you do buy, just make sure you don't sell or won't be forced to sell any time soon - at least until this stuff is sorted out more definitively? GSJ
  9. JIT

    Another Blow to Hybrids

    Not fighting, just a difference of opinion. Its so important to see both sides of the investing coin. With respect to HDT's, until recently on this forum, we have only seen one side. Now, with alternative point of views being presented (eg. Ronin, Twitch, Julia...), it makes it much easier for...
  10. JIT

    Another Blow to Hybrids

    Discussion Questions... Hi Julia and others, I just read through most of the NTAA document. Just a few points and questions regarding income units and negative gearing with property in HDT's, to help clarify my understandings: - If you use this structure for tax benefit AND asset...
  11. JIT

    Another Blow to Hybrids

    Yes, I agree, and I think one must be careful in distinguishing 'capital growth', 'capital gain', 'capital distributions' and 'capital' in these discussions... GSJ
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