Cyter Tax is the AI for Australian tax advisors — structuring, CGT planning, Part IVA and trust research with cited, verifiable sources in minutes.
Ask questions here to get answers about laws, rules and how they've been applied.
Enter a question
A complete research workflow — ask, verify, write up, and download.
One folder per client, one project per matter. Everything stays structured and easy to find.
Client X Pty Ltd
3 projects
Search the full tax corpus or narrow to statutes, case law, or specific ATO ruling types.
Ask in plain English, get answers traced by a citation linked to the statute, ruling or case.
Ask questions here to get answers about laws, rules and how they've been applied.
Hover on any citation to verify — nothing made up.
Unfrankable Distributions from Share Capital Account: A distribution is unfrankable if it is sourced, directly or indirectly, from a company’s share capital account. 3 This applies to distributions that constitute a reduction or return of share capital, even if labelled as a dividend. 4 The definition of a share capital account includes an account a company keeps of its share capital, or any other account where the first amount credited was share capital. 5 Therefore, any portion of a selective buyback that is a return of share capital cannot be franked.
Benchmark Franking Percentage: A corporate tax entity franks a distribution by allocating a franking credit to it. 6 The benchmark franking percentage is a key concept in determining the maximum franking without penalty. If an entity franks a frankable distribution at a percentage that exceeds its benchmark franking percentage for the franking period, it is liable to pay over-franking tax. 7 This effectively sets the benchmark franking percentage as the maximum franking allowed without incurring a penalty.
Send any passage to ThoughtPad with one click. Build your research document as you go.
If a trustee has a power to change the beneficiaries under a trust and exercises that power, does it cause a CGT event to occur?
In Short: A trustee's valid exercise of a power to change beneficiaries under a trust generally does not cause a Capital Gains Tax (CGT) event to occur, specifically CGT events E1 or E2, unless the change terminates the existing trust and creates a new one, or causes an asset to be held under a separate charter of obligations.
Relevant Legislation: Income Tax Assessment Act 1997 (Cth), s 104-5 — provides a summary of CGT events, including E1, E2, E5, E6, E7, E8, and A1.
Relevant Case Law and Ruling: TR 2018/6 — confirms that amending a trust's vesting date through a valid exercise of power in a trust deed or court approval does not trigger CGT event E1.
CGT Events E1 and E2: A change in the terms of a trust, including the addition or exclusion of beneficiaries, pursuant to a valid exercise of a power in the trust deed, will generally not cause CGT event E1 or E2 to happen.
CGT Event E5: CGT event E5 occurs if a beneficiary becomes absolutely entitled to a CGT asset of a trust as against the trustee. For a beneficiary to be absolutely entitled, they must have a vested and indefeasible interest in the entire trust asset and the right to call for its transfer.
CGT Events E6 and E7: CGT event E6 happens if a trustee disposes of a CGT asset to a beneficiary in satisfaction of an income right, and E7 happens for a capital right.
Passages you send will appear here
Enter the client facts. Click Write Up. Get a polished, cited document ready for review.
Optionally provide the facts of your situation for fact-application analysis. Leave blank to reorganise and professionalise the content.
Take your Cyter Tax research and apply it straight into an existing client document. The Augmenter marks up the document in tracked redlines — pulling in new findings, citations, and tightened wording — so you can review and accept every change.
Tell the Augmenter what to change. It will mark up your existing document with tracked redlines so you can review every edit before accepting.
Export to Word with full citations, partial citations, or none — your choice.
Advisory work is where tax law gets hardest. The client does not want a return prepared; they want a structure, a position, or a plan. Cyter Tax is built to support the research phase of advisory engagements, where the cost of being wrong is high and the cost of over-researching is also high.
Generic AI tools consistently fail at tax advisory work for the same reason: they sound confident but cite invented sources. In tax advisory, invented sources are not a minor nuisance — they are a professional liability. Cyter is built to never produce an uncited claim or an unverifiable citation. If the corpus does not support a claim, the response says so.
The practical effect is that advisory research becomes faster without becoming less rigorous. You still read the primary sources; you just spend dramatically less time finding them. Partner-level review focuses on strategic judgement, not on cite-checking junior work.
Cyter does not replace your CCH, Thomson Reuters or similar tax advisory subscriptions — those products contain commentary and worked examples that remain useful for advisory work. Cyter complements them by providing direct, cited access to the primary source material (statutes, rulings, cases) in response to specific questions, with the citation structure lawyers and accountants expect.
Try Cyter Tax free with 5 queries on the full Australian tax corpus.
No credit card required. 5 free queries to try it out.