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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 is an AI research platform purpose-built for Australian tax firms. Instead of scaling headcount to handle research volume, firms use Cyter to produce reliably cited tax analysis on demand — across every partner, manager and associate.
Tax firms operate under a cost-to-serve problem. Every client question costs real time: juniors dig through the Income Tax Assessment Act, managers cross-check ATO rulings, partners verify case law. Cyter compresses that workflow from hours to minutes, while keeping every citation linked to the source statute section, ruling paragraph or judgement paragraph.
Because the corpus is trained on Australian tax law specifically — ITAA 1936, ITAA 1997, GST Act, FBT Act, TAA 1953, ATO ruling types (TR, TD, GSTR, MT, LCR, PCG, PS LA, EPA) and court decisions (HCA, FCA, select state supreme courts, ART) — outputs sound and cite like a senior associate, not a general chatbot.
Every claim in a Cyter response points to a specific source page and quoted passage. There is no hallucinated citation: if Cyter cannot find a statutory or judicial source for a claim, it says so. This is the key reason tax firms trust it over general AI tools — partners can sign off on Cyter-assisted work without a second-guess cross-reference.
Firms typically deploy Cyter alongside their existing research subscriptions. It does not replace tax counsel or professional judgement. It replaces the hours spent on initial research, so your people spend more time on analysis and client strategy.
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