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  1. M

    Another Blow to Hybrids

    nonrecourse, lets keep the personal element out of our 'bites' and focus on the topic at hand. Discussing HDTs is the point of the thread, not bashing people around and taking the discussion into the gutter. I enjoy having Dale talk on this thread, and I am sure he does too. We have already...
  2. M

    Another Blow to Hybrids

    For those reading, Matthew Burgess is a partner at McCullough Robertson lawyers. He called their interpretation a "conservative position on an aggressive product", being one where the unit holder made a decision when a property could be sold. As for how he came across....he will probably...
  3. M

    Another Blow to Hybrids

    Would there be any shortcomings with that approach Dale? Such as the application of Part IVA and the Commissioner's views from IT 2864?
  4. M

    Another Blow to Hybrids

    Private Binding Ruling 28993.
  5. M

    Another Blow to Hybrids

    I was at the Hilton seminars on April 3-4 in Brisbane. Was it Matthew Burgess who was the HDT solicitor? I won the bottle last year with my questions about the gift and loan back strategy. There were only three questions asked of him about hybrids, the only woman who asked him a question was...
  6. M

    Another Blow to Hybrids

    Asset protection is a double edged sword. You can raise the issue of asset protection being a reason for setting up a HDT and attempt to avoid Part IVA. If the argument fails and Part IVA succeeds, you lose. If the argument succeeds, the ATO states that asset protection is for private...
  7. M

    Another Blow to Hybrids

    I attended a recent NTAA seminar where hybrids were discussed in detail. As a result of concerns raised by members, the NTAA released to the public their seminar notes on hybrids. Those who wish to look at the NTAA's opinion on hybrids can have a look at this link. They are quite technical...
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