OVERVIEW In April 2025, the Full Court of the Federal Court of Australia handed down its decision in Merchant v Commissioner of Taxation [2025] FCAFC 56. This decision was appealed to the High Court, whose decision is still to be finalised. This article is therefore prepared on the basis of the Full Court decision and [read more]
Background This article covers recent changes to the UK Inheritance Tax (IHT) regime, involving changes to the calculations of the value of a person’s estate such that it includes unused pension funds and pension death benefits (Pension Benefits). We also discuss the impact that binding death benefit nominations (BDBNs) have for IHT purposes prior to [read more]
The Albanese Government’s deal with the Greens to secure passage of the first tranche of its major tax changes has placed limited recourse borrowing arrangements (LRBAs) back in the spotlight. We outline below the changes to the LRBA rules that apply from 10 August 2026 reflected in the Treasury Laws Amendment (Tax Reform No. 1) [read more]
The Albanese Government’s deal with the Greens to secure passage of the first tranche of its major tax changes has placed limited recourse borrowing arrangements (LRBAs) back in the spotlight. We outline below the press releases in which both parties reached agreement on changes to the LRBA rules, and discuss the amendment moved by Senator [read more]
The Government’s proposed minimum 30% non-refundable tax credit (NRT Credit) on trustees of discretionary trusts (DTs) announced in the Federal Budget on 12 May 2026 will have a significant impact on tax planning and investment structures, including impacting SMSFs. The Treasury Consultation Paper (C-Paper) in respect of these changes was released on 8 July 2026 [read more]
This article explores the impact on negatively geared SMSFs from: the new limited recourse borrowing arrangement (LRBA) related party interest rates; and the changes in the 2026–27 Budget. New LRBA related party interest rates Many SMSFs that borrow do so from a related party lender. In this case, SMSFs often choose to replicate the safe [read more]
Accounting firms that set up and manage complex tax structures, such as family discretionary trusts (FTs), unit trusts and self managed superannuation funds (SMSFs), should be aware of the relevant clauses of their PI policy. The ATO’s renewed focus on certain tax issues relating to these structures, including non-arm’s length income (NALI), Division 7A loans, [read more]
On 30 June 2026, Parliament passed important amendments to section 17A of the Superannuation Industry (Supervision) Act 1993 (Cth) (SISA) as part of the Treasury Laws Amendment (Delivering an Efficient and Trusted Tax System) Bill 2026 (Bill). What are the trustee/member rules Section 17A of the SISA sets out the rules that determine whether a superannuation [read more]
The Albanese Government’s deal with the Greens to secure passage of the first tranche of its major tax changes has placed limited recourse borrowing arrangements (LRBAs) back in the spotlight. We outline below the press releases in which both parties reached agreement on changes to the LRBA rules, and discuss the amendment moved by Senator [read more]
A recent court decision held that a change of director in a company could give rise to duty on the value of any dutiable property held by trustee of a unit trust. After the unfavourable Victorian Civil and Administrative Tribunal (VCAT) decision in Tao v Commissioner of State Revenue (Review and Regulation) [2024] VCAT 637, [read more]
