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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.
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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.
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Cyter Tax generates structured tax analysis in response to any question about Australian tax law. Instead of raw search results, you receive a synthesised response organised as In Short, Relevant Legislation, Relevant Case Law and Rulings, and Explanation — with every claim footnoted to a verifiable source.
Every Cyter response follows a consistent legal memo structure. The "In Short" section gives a two to four sentence conclusion without citations — suitable for quick client communication or internal triage. "Relevant Legislation" lists the statutory provisions that apply, one line per provision, each pointing to its ITAA 1997 or other Act section. "Relevant Case Law and Rulings" does the same for the decided cases and ATO guidance material.
The "Explanation" section is the analytical core. It walks through how the provisions actually apply to the question, integrating legislation, rulings and case law into a coherent argument. Every factual claim in the Explanation is footnoted to a specific source paragraph with a verbatim quote from that source. This makes the analysis both readable and auditable — you can verify any claim without leaving the response.
Cyter is most useful where the law is settled enough that the analysis is mostly about finding and applying the right provisions. For truly novel or edge-case issues — areas where the existing sources do not resolve the question — Cyter will tell you the sources are silent or inconclusive, rather than fabricating analysis. This is the honest version of an AI tax tool.
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