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These two factors are irrelevant to determining whether land is trading stock. Mrs Hulk owns the land and has always owned the land. Entity use doesn't change outcomes (other than loss of the main res exemption or a CGT discount). You don't have to change ownership to have a CGT event. ie K4...

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Me too and I'm a tax adviser.:D Definitely a bit in such a simple question. I would think that given the potential for issues with pro-rata main residence exemption, apportionment, CGT, GST, separate CGT assets ? (1, 2, 3 or 4) etc its well worth obtaining full and complete personal advice...