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Ronin, You indicate that the units are redeemed for $5 when purchased for $500,000. Those of us who recommend and implement the use of HDT's do not recommend this strategy at all. In fact if you paid $500K for the special income units then the trustee is required to repay you your initial...

Part IVA only applies where the "sole or dominant purpose is to obtain a taxation benefit". For most of my clients the sole or dominant reason for the use of a HDT is not to obtain taxation benefits. It is to provide asset protection and more important estate planning benefits (through trust...

No problems Ronin I'm sure they would be willing to discuss these areas with you. I understand your concerns but the same issues could be applied to a discretionary trust which holds a business asset. The trust has the potential to distribute both income and capital at its discretion. On the...

Ronin, If you would like to discuss the structures and possible Part IVA implications may I suggest a consultation with either : Chris Bowman Director of Tax William Buck 8263 4000 Chris Batten Specialist Tax Consultant to the mid-tier firms 9231 5111 Margaret Antunes...

We could debate these things back and forth ad infinitum. We have clients who have a HDT for properties and have been audited. The audit did not result in any breach of the law. The auditors do however seem to be concerned as to whether the property is being used as the individual's main...