WARNING:
This Digest was prepared for debate. It reflects the legislation as
introduced and does not canvass subsequent amendments. This Digest
does not have any official legal status. Other sources should be
consulted to determine the subsequent official status of the
Bill.
CONTENTS
Taxation Laws Amendment (Trust Loss and Other
Deductions) Bill 1997
Date Introduced: 1 October 1997
House: House of Representatives
Portfolio: Treasury
Commencement: Royal Assent. However, refer to the
end of the main provisions section for the date of application for
the various measures.
The Bill will impose a general restriction on trusts claiming a
deduction for prior year losses. Losses will be able to be deducted
for certain trusts where the relevant provisions of the Bill are
complied with. The Bill also exempts certain categories of trusts
from the denial of the deduction, with family trusts (as defined)
being one of the more important categories of exempt trusts. As
well, many investment vehicles which use a trust structure, such as
complying superannuation funds, will also be exempt from the
proposed rules.
The treatment of losses incurred by trusts in previous years,
which are currently allowed as a deduction for the trust, was
placed on the taxation agenda in the 1995-96 Budget.
Prior to the Budget announcement, losses incurred by trusts
could be carried forward to offset income in later years unless the
trust deed or a law required that the loss be met from the capital
of the trust. There was no restriction on the period that the
losses may be carried forward. Also, while companies were required
to satisfy either the continuity of business or continuity of
ownership tests to be able to carry forward losses, trusts were not
required to satisfy either of these tests, so that the trustee or
the matters that the trust may deal in may have altered from the
time that the loss was incurred and the deduction is claimed in a
later year or years. This led to a trust being a more favourable
vehicle than a company in many circumstances where the person
finally entitled to the income wishes to minimise their tax. The
1995 Master Tax Guide, published before the 1995 Budget
announcement, commented:
The absence of restrictions on the deductibility of carry
forward trust losses has given rise to some trafficking in 'loss
trusts'. These transactions normally involve an alteration to the
relevant deed of trust, the appointment of a new trustee or,
alternatively, the acquisition of a corporate trustee by new
shareholders...(1)
The major reasoning for the desire to use previous years losses
is that they can generally be acquired for less than the value of
the loss to the holder of the trust. For example, if a trust has
substantial prior losses but little income that the losses can be
offset against, the trust will not be able to access the full value
of the potential deductions from the prior losses. However, if a
trust with sufficient income to be able to offset the prior year
loss deductions were to acquire the prior year losses of the other
trust, it would be able to fully utilise the deductions available
from the prior year losses. In such circumstances, it is in the
interests of both trusts to reach an agreement regarding the value
of the prior year losses to the acquiring trust, which will
generally be a price between the value to each trust. In such
circumstances both trusts will benefit but the revenue will
suffer.
However, it should be noted that there are many reasons not
connected with taxation for a business, particularly a small or
medium family business, to be established on a trust rather than
company basis. A major reason for the use of a trust rather than a
company in a family business is the ability of discretionary trusts
to vary their distributions according to the needs of the various
beneficiaries and to include distant relatives as beneficiaries
even if they do not receive regular distributions from the trust
(although this can also be used to distribute income to those in
the lowest tax position to minimise the amount of total tax
payable).
The 1995-96 Budget announced substantial changes to the ability
of trusts to carry forward their losses in an attempt to protect
the revenue. The major feature of the proposed changes was to place
trusts in much the same position as companies with regard to prior
year losses. The main differences between the treatment of
companies and trusts in the proposals was that:
- the continuity of business test would only apply to corporate
unit trusts and public trading trusts;
- an 'income injection' test would apply to deny a deduction
where income, or other consideration, is injected into the trust
that is to take advantage of the loss, so that a loss cannot be
acquired, funds injected into the trust and income offset by the
losses; and
- there would be special rules for family trusts and
discretionary trusts.
The proposed changes, along with a number of other measures,
were contained in Taxation Laws Amendment Bill (No. 4) 1995 but the
provisions relating to trust losses were notpassed by the Senate
and the Taxation Laws Amendment Act (No. 4) 1995 did not contain
the provisions relating to trust losses. Among the reasons for the
Senate rejecting the provisions dealing with trust losses were:
- the tests contained in the Bill were such that there was doubt
as to whether genuine business losses could continue to be carried
forward;
- the measures would have a significant impact on small
businesses operated through trusts;
- there would be significant compliance costs for large trusts
which would have to trace the underlying interests in the trust to
satisfy the continuity of ownership test; and
- there was insufficient time to properly scrutinise the
measures.(2)
The explanatory memorandum to that Bill estimated that the
measures would raise $90 million in 1995-96, $185 million in
1996-97, $155 million in 1997-98 and $65 million in 1998-99.
The legislation lapsed with the dissolution of Parliament for
the 1996 General Election. The policy of the new government was set
out in the 1996 Budget when it was announced that the policy would
be pursued but would be modified. Major changes related to:
- easing of the rules relating to family trusts so that if an
eligible trust elects to be treated as a family trust there will be
no need for the trust deed to be changed to remain eligible to
carry forward losses;
- allowing a fixed trust that is more than 50% owned by a
discretionary trust to continue to carry forward losses;
- modification of the income injection test;
- easing of rules where trusts are used as a legitimate business
vehicle;
- changes in the rules relating to the tracing of the ultimate
owners of trust to reduce compliance costs; and
- the adoption of a number of amendments proposed by the former
government.(3)
It was also proposed that the changes would have effect from the
date of the original announcement, 9 May 1995. However,
transitional provisions for family trusts will be extended until 1
July 1997.
An exposure draft of the proposed legislation was released in
February 1997. In a response to the draft legislation, the
Australian Taxpayers' Association (ATA) commented: 'Legislation
remains extremely complex and still has an undue impact on the vast
majority of farms and small businesses with no involvement in loss
trafficking.'(4)
Further modifications to the proposed rules were announced in
the 1997-98 Budget. The main change related to family trusts with a
contribution of funds into the trust not to be considered a breach
of the income injection test if the contribution is made by a
member of the family. In a related measure, the definitions of
'outsider' and 'family member' were altered. The change in the
definition of what constitutes a family trust has received
considerable attention. The main differences in the definition
proposed to operate after 13 May 1997 and that contained in the
original 1995 Bill is that former spouses and their relatives are
not included in the definition of a family in this Bill, the aunt,
uncle and great grandparent of the test individual were included
under the 1995 Bill but excluded under this Bill and that to be
eligible under the 1995 Bill a child of a parent, brother, sister,
nephew or niece of the test individual would have only been
included in the definition of a family if they were capable of
benefiting on the death of the test person. Under this Bill there
is no requirement that such people be capable of benefiting under
the death of the test individual. The original definition will
apply until the date of the announcement of the changes to the
definition of a family. The Press Release announcing the changes
also noted that the Government was continuing to examine other
matters than had been commented on since the draft legislation was
introduced. As a result of these considerations, there have been
some further, relatively minor, changes to the legislation before
it was introduced into Parliament.
The legislation has received some unfavourable comments:
ATA maintains that the Bill will adversely effect small
businesses and farmers. Principal to the ATAs concerns are who will
be considered to be family members for a family trust to be able to
carry forward losses. A Press Release from the ATA states:
The Government has created the extraordinary situation that
certain family members who:
- could claim or successfully dispute an inheritance from a
deceased estate;
- could be the subject of child support obligations under the
Child Support Assessment Act; or
- are dependants for superannuation purposes;
are not allowed to be members of family trusts under the
proposed legislation.
This means that many small businesses will have to chose
between:
- the potential loss or postponement of legitimate claims for
losses incurred during business downturns (which may threaten the
very viability of those small businesses); and
- removing key family members from a share of the present or
future beneficial ownership of the business.(5)
However, it must be noted that as the definition of a family is
expanded the possibility of a family trust being used as a tax
minimisation vehicle will increase.
In regard to the general tax position of trusts, as distinct
from the position regarding the carrying forward of tax losses
which is addressed by this Bill, the Commissioner of Taxation, in a
speech to CEDA on 10 September 1997 put forward the view that
trusts should be taxed in the same manner as companies. This view
was based on the argument that both companies and trusts were
extensively used for business purposes and the choice of the most
appropriate vehicle should not be based on taxation considerations
but on the different nature of the two entities. The Commissioner
also indicated that a discussion paper on the general issue of
taxation of trusts would be released.
While this Bill contains differences to the original proposals,
the revenue implications are substantially the same as those for
the original proposals. The explanatory memorandum to the Bill
estimates that this Bill will save $90 million in 1995-96; $185
million in 1996-97; $160 million in 1997-98; $75 million in
1998-99; and $20 million in each of the next two years.
Schedule 1 of the Bill will insert a new
Schedule 2F, titled Trust losses and other deductions, into the
Income Tax Assessment Act 1936 (ITAA).
Exempted Trusts
Exempted trusts will not be subject to the rules contained in
the Bill. An exempted trust is one which during the period in
question:
- is a family trust;
- is a complying superannuation fund, complying approved deposit
fund or a pooled superannuation fund;
- is the trust of a deceased estate during the period between the
time of death to the fifth anniversary of the death; or
- is a fixed trust that is a unit trust and people who are tax
exempt have fixed entitlements for their own benefit to all of the
income and capital of the tax (proposed section
272-100).
Family Trust
A significant amount of the comments on this Bill concern the
effect it will have on family trusts, particularly those that are
used to operate small businesses and farms. The term is defined in
proposed section 272-75 to be a trust where an
election under proposed section 272-80 has been
made. This proposed section allows a trust to make such an election
when it satisfies the family control test. The family control test
is contained in proposed section 272-87 and
provides that the trust must consist of:
- a primary trust representative nominated in the election (this
alleviates the need for trust deeds to be changed); or
- members of representative person's family (which is defined in
proposed section 272-95 to be a parent,
grandparent, sister, brother nephew, niece, child or child of a
child of the person or their spouse and the spouse of any of the
above people, including the representative person, but note that a
different definition applies prior to the 1997 Budget - refer to
the applications provision at the end of this Digest); or
- a combination of the above categories; or
- except where the above people have more than 50% control of the
income or capital of the trust, people in the above categories and
a legal or financial adviser to any members of the family.
(It may be noted that the definition of a family excludes
certain groups such as cousins.)
In addition, the members of the trust must have a degree of
control of the activities of the trust. This will be satisfied in a
number of situations, including
- the group has the power to obtain the beneficial enjoyment of
the capital or income of the trust;
- the group can control the use of the capital or income of the
trust;
- the group can gain either of the above two matters;
- the trustee is either accustomed or obliged to act in
accordance with the directions or wishes of the group;
- the group is able to remove the trustee; or
- the group has a stake in more than half of the income or
capital of the trust.
If a trustee of a family trust elects to have the trust treated
as a family trust, a company, partnership or trust may elect to be
included in the family group if it satisfies the family control
test at the end of the year. To satisfy the family control test,
such a body must consist of either the individual specified in the
election, one or more members of the person's family or the
individual and one or more members of that person's family, who
have fixed entitlements to more than 50% of the capital or income
of the company, partnership or trust.
Proposed sections 266-40 and 266-45 contain the
tests that must be satisfied for a deduction for loss to be
claimed. The first test is the 50% stake test. This test will be
satisfied for a period where at the beginning and end of the period
the same individuals have fixed entitlements to more than 50% of
the income, or the same individuals (who may be different people to
those entitled to the income) have fixed entitlements to more than
50% of the capital of the trust (this is a form of a continuity of
ownership test). If this test is not satisfied, the trust must meet
the non-fixed trust stake test. This test contains four conditions
that must be met.
- At all times during the period under consideration non-fixed
trusts (ie discretionary trusts) held fixed entitlements to at
least 50% of the income or capital of the trust; or a fixed trust
or company held, directly or indirectly, all of the fixed
entitlements to the income and capital of the trust and non-fixed
trusts held fixed entitlements to 50% or more of the capital or
income of the holding trust or company.
- The entity holding the fixed entitlements must have held those
interests during the period under consideration.
- At the beginning of the period under consideration, individuals
must not have held more than 50% of the capital or income of the
trust.
- The final condition relates to the whether other provisions of
the Bill would prevent the deduction being claimed if the non-fixed
trust was a fixed trust. The actual rule to apply depends on the
provision under which the non-fixed trust is claiming the deduction
on the basis that it satisfies the test.
Family Trusts Making a Distribution Outside the Family
Where a trust has elected to be a family trust and a
distribution is made, or an entitlement is given, to a person who
is neither listed in the trust deed nor a member of the family
group; or such a distribution or entitlement is made to a person
who falls within the trust deed or family group and is the trustee
of another trust, tax, calculated according to the Family Trust
Distribution Tax (Primary Liability) Bill 1997, will be payable.
Similar rules will apply where the distribution is made to an
intermediatory trust, partnership or company which then makes a
distribution as described above. The family group is defined to
be:
- the trustee and the members of their family;
- an interposed entity where an election has been made by that
entity to be included in the family group;
- entities owned by the family;
- listed funds, authorities and institutions (these are bodies
listed in the ITAA and includes bodies such as research
institutions, funds that provide money to public or non-profit
hospitals and funds that provide money for certain educational
institutions);
- certain tax exempt bodies under the ITAA (such as religious,
scientific and charitable institutions);
- if the primary individual and all of their family are dead -
the estate of members of the family group will be the family group;
and
- a person who has acquired a threshold interest in a small or
medium business that has elected to be a member of the family
group, where the person is an Australian financial institution or a
subsidiary of an Australian financial institution which is not an
associate of the small or medium business (defined in the ITAA on a
number of ground including a value of $50 million or less).
Proposed Division 271 also contains provisions
that will allow the Commissioner to request information from the
primary trust or an interposed body relating to distributions to
non-residents. If tax becomes payable under the proposed Division
and the trust is a non-residents family trust, the Commissioner has
determined that it is unlikely that the tax will be paid and the
trustee of the trust is a non-resident or the management and
control of the trust is outside Australia, then:
the trustee/s of a trust, or director/s of the company if the
trust is a company, who has a fixed entitlement to income or
capital of the trust, will be liable to pay the amount of tax if,
after considering the matters contained in proposed section
272-30 the Commissioner is of the opinion that the trust
or company is holding the funds for that individual's benefit.
Similar rules apply where the interposed entity is a
partnership. Additional tax will apply where the tax due is not
paid within 60 days of it becoming due. The rate of additional tax
will be 16%. The rules aim to ensure that if a family trust
attempts to use an overseas entity to channel funds through and use
the family trust rules to gain an otherwise unallowable deduction,
extra tax will be imposed on the Australian entity that is
sufficiently connected with the funds. This is also achieved by
making local trustees and directors personally liable unless they
have sufficient reasons to be excluded.
In certain circumstances where a family trust has an interest in
another trust, the family trust may be required to provide certain
information to the Commissioner if they are to take advantage of
the concessions available for family trusts. This will be where the
following conditions are met:
- the trust deducted prior year losses, did not work out its
income in accordance with Division 268, a deduction has been
claimed for a debt and would not have been able to claim the
deductions if it had not satisfied the relevant provisions of this
Bill;
- the Commissioner must be satisfied that the conditions would
not have been satisfied unless one or more of the trusts was a
family trust;
- in relation to at least one of the family trusts, either the
trustee is a non-resident or the central management and control of
the trust is outside Australia; and
- notice is given by the Commissioner for the production of
information within the later of either 5 years after the end of the
year of income for which the deduction is claimed and the period
for which records are required to be kept (generally 5 years but
this may be extended in certain cases where the assessment process
has not been completed).
Where the conditions are met, the Commissioner may require the
trustee to provide information on present entitlements and the
distribution of the capital and income of the trust. If the
information is not supplied, the trust will be taken to have never
satisfied the conditions necessary to carry forward the losses and
a fixed trust will be required to use Division 268 to determine its
income.
Fixed Trusts
Proposed section 266-25 provides that where a
trust is in a position to deduct losses from previous years, was a
fixed trust during the year of income, was not a widely held trust
and was not an exempt trust, the trust will not be able to claim a
deduction for prior losses unless it meets the conditions contained
in proposed sections 266-40 or 266-45 (see above).
Fixed trust: defined in proposed section 266-65
to be a trust where the beneficiaries have a fixed interest in the
trust. This may be compared to a discretionary trust where the
trustee determines the distribution to the various
beneficiaries.
Widely held trust: This term is defined to be a unit trust that
is a fixed trust and in which up to 20 individuals do not have
control of 75% or more of the income or capital of the trust.
Unlisted Widely Held Trusts
An unlisted widely held trust is an unlisted unit trust that is
a fixed trust where 20 or fewer individuals do not have a right to
75% or more of the capital or income of the trust and the rights
attached to the units cannot be varied or abrogated so as to lead
to 20 or fewer individuals having such rights. An unlisted unit
trust will be taken to be very widely held, and so notwidely held,
if it has at least 1 000 unit holders, all of its units have the
same rights and, if the units are redeemable, the price is
determined on their net asset value. As well, a trust will not be a
widely held unit trust if it is a wholesale widely held trust (ie.
a unit trust at least 75% of the units are held by certain types of
investment trusts and companies and the amount subscribed by each
unit holder is at least $500 000). Proposed section
266-75 will also apply to a trust that was an unlisted
widely held trust at some time in the loss year and was a listed
widely held trust at all other times in the year.
The operative provision of proposed section
266-75 is that such trusts will not be able to claim
losses unless proposed section 266-90 is
satisfied. The test is that if abnormal trading in the trust has
occurred (see below), or the financial year has ended the trust
must have passed the 50% stake rule (see above) at the beginning
and end of the period under consideration. Abnormal trading is
defined in proposed sub-division 269-B to be
when:
- there is abnormal trading in the units of the trust having
regard to the timing of the trades, the number of units traded, any
connection between the trade and prior trading;
- if the trustee knows or reasonably suspects that there is
trading relating to an acquisition or merger;
- 5% or more of the units of the trust are traded in a single
transaction;
- there is suspected trading of 5% or more of the units of the
trust. (The definition of when this will occur is quite vague and,
as it comprises an objective, reasonably suspect, test could be the
subject ofsignificant legal action if it is disputed that the
trustee did not reasonably suspect that the trading was part of
abnormal trading. The test to be applied is that the trustee knows,
or reasonably suspects, that a person either with or without
associates have acquired or redeemed 5% or more of the units in the
trust in 2 or more transactions and that they would not have done
so if the trust did not have a loss or other deduction);
- if more than 20% of the units in the trust were traded within a
60 day period;
- if the trustee knows or reasonably suspects that a stakeholders
interest in the trust has, during the period under consideration,
fallen below the 50% stake holding;
- if a unit trust that has fixed entitlements to all of the
capital and income in another trust and this arrangement changes it
will be taken to be abnormal trading unless there is another trust
that continues to hold the right to the income and capital of the
other trusts (ie. the final trust continues to have rights to the
income and capital of the other trusts so that there is no change
in the final distributions of the trusts); or
- however, if there is there is an issue of additional units in
proportion to current holdings and this would result in any of the
above rules being breached, it will not be considered to be
abnormal trading.
Proportional deductions are allowed where the trust satisfied
proposed section 266-90 for the period of the year
for which the deduction is allowable.
If proposed section 266-90 does not apply,
special rules will apply in the calculation of income and losses.
Proposed subdivision 268-B provides for a year to
be divided into different periods with each period ending at the
time that there is abnormal trading in the units of the trust or
when the 50% stake test is not satisfied. Proposed section
266-95 allows for proportional deduction of a loss for
those periods when the test was satisfied.
For a widely held trust, a deduction will be denied for past
losses unless the conditions contained in proposed section
266-125 are satisfied and proposed section
266-135 does not deny the deduction. The conditions that
must be satisfied are that:
- there was no abnormal trading in the trust; or
- there was abnormal trading but after the abnormal trading the
50% stake test was still satisfied or the same business test was
satisfied (basically this will be where the trust carries on the
same business before and after the test time, does not derive
income from a business of a different kind and did not start a new
business during the test period).
Proportional deductions will be allowed for periods during which
the conditions are satisfied (proposed section
266-130).
The effect of abnormal trading on unlisted very widely held
trusts and wholesale widely held trusts is dealt with in
proposed subdivision 266-E. A deduction for prior
losses will be denied unless either of the following conditions are
met:
- there was no abnormal trading during the test period; or
- there was abnormal trading but the 50% stake test was satisfied
during the test period.
If the conditions are not satisfied, the trust will be required
to calculate its income and losses in accordance with
proposed Division 268 (see above).
Non-fixed Trusts
A non-fixed trust will not be able to claim prior losses unless
the following conditions are met:
- if the trust made a distribution of income in the year of
income or within 2 months after its end and made a distribution
within any of the earlier 6 previous years, or distributed capital
within those times, then the pattern of distribution test must be
satisfied. The pattern of distribution test is dealt with in
proposed subdivision 269-D and will be satisfied
where the trust distributed at least 50% of the income
distributions to the same people in all distributions during the
test year and the trust distributed 50% of any capital
distributions to the same people in all distributions of capital
made during the test year (the people to who the income and capital
may be distributed in satisfying this test may be different so long
as each group remains the same). The year under consideration will
generally be the year in which the distribution/s are made plus 2
months after the end of that year, although previous years may
apply in certain circumstances. There are also special rules where
all the funds available have not been distributed and people have a
fixed entitlement to a share of that income (in which case it will
be deemed to have been distributed in accordance with the fixed
entitlement); where no distribution is made because of an
individuals death or breakdown in their marriage, in which case
certain fixed distributions are to be ignored (ie if because of
either of these events the distribution eventually goes to a person
other than when the original distribution was made).
There is also an anti-avoidance test.
The deduction for prior year losses will also be denied if the
control test is not satisfied. To satisfy this test the follow must
occur:
- the trust has not failed the pattern of distribution test in
previous years;
- during the test period, the same person or persons held a stake
in more than 50% of the income or capital of the trust; and
- a group must not begin to control the trust. This is defined in
proposed subdivision 269-E to be if the group can
exercise power to obtain benefits from the trust, the group is able
to control the application of the income or capital of the trust,
the trustee is accustomed, obliged or otherwise acting in
accordance with the wishes of the group, the group can appoint or
remove the trustee, or the group acquires 50% or more of the
capital or income of the trust. In certain cases of death, marriage
breakdown and incapacity, changes in the group will be disregarded
so long as the beneficiaries remain the same before and after the
new group takes control.
If the trust is a non-fixed trust and there is not a continuous
more than 50% stake in the income or capital during a test period
and a group has begun to take control of the test, the income and
deductions of the trust must be worked out in accordance with
proposed subdivision 268.
Anti-Avoidance
Proposed division 270 contains general
provisions dealing with situations where an outsider of the trust
has, directly or indirectly, provided a benefit to the trust and
the trust has provided a benefit to the outsider and the events
occurred to receive an allowable deduction. If such a scheme
exists, the deduction will be denied.
Application
Generally, the provisions will have effect where the income year
is 1994-95 or later years. However, where the relevant provision
refers to a test period, as do the operational provisions, the
provisions are taken to commence at the time of the 1995 Budget
announcement. For non-fixed trust distributions, the Bill will
apply to distributions after 28 September 1995. Amendments relating
to losses from foreign trusts will apply from 1 October 1997. The
definition of family contained in the Bill will apply from Budget
time (7.30 pm on 13 May 1997) and prior to that date a family will
be taken to be:
- the test individual and their spouse or former spouse;
- the parent, brother, sister child nephew or niece of the test
individual, their spouse or former spouse;
- a child of any of the above who is capable of benefiting on the
death of any of those individuals;
- a grandparent or great-grandparent aunt or uncle or the test
individual,
- a child of the test individual; and
- a spouse or former spouse of any of the above.
- CCH, 1995 Australian Master Tax Guide, p. 1311.
- Senate, Hansard, 1 December 1995.
- Treasurer, Press Release, 20 August 1996.
- Australian Taxpayers' Association, Press Release, 8
October 1997.
- Ibid.
Chris Field
11 November 1997
Bills Digest Service
Information and Research Services
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is taken to ensure that the paper is accurate and balanced, the
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(IRS). Advice on legislation or legal policy issues contained in
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and their staff but not with members of the public.
ISSN 1328-8091
© Commonwealth of Australia 1997
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