This paper covers:
- analysis of the maximum net asset value test
- the ‘connected with’ test - It’s all about control
- control of an entity other than a discretionary trust - Particular trust issues
- control of a discretionary trust - The “trustee reasonable to expect to act” control rule
- control of a discretionary trust - Pattern of distributions rule
- Commissioners exercise of discretion - 328-125(6)
- the significance of the significant individual test
- timing Issues with distributions from trusts and satisfying the significant individual test
- the trust streaming measures
- structuring issues and ordering of the concessions.