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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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Research is the costliest phase of any tax engagement. Cyter Tax is designed to collapse it — surfacing the relevant statutes, rulings and cases for any Australian tax question in under a minute, with every claim cited to source. It is the opposite of the "ask ChatGPT" problem: instead of confident-sounding answers with invented citations, you get cautious analysis with real, verifiable ones.
Traditional research is a lookup workflow. You think of a search term, scroll through database results, skim each document, write down findings and repeat. Cyter replaces that with a question-answer workflow. You ask "how does the CGT discount apply to trusts that distribute capital gains?" and Cyter returns a structured analysis citing section 115-215 of ITAA 1997, TD 2019/D6, and the relevant beneficiary-streaming provisions — all within one response.
Because the AI performs semantic search rather than keyword matching, it finds sources even when the legislation uses different terminology than your question. Ask about "commercial debt forgiveness" and it returns Division 245 content, even though the Act calls it "forgiveness of commercial debts". Ask about "phoenixing" and it returns the Commissioner's views on section 109 and various ATO rulings even if "phoenix" doesn't appear verbatim in the source.
Cyter does not replace professional judgement, and it does not replace the need to read the primary sources for any advice you will send to a client. What it replaces is the hours spent locating the primary sources in the first place.
Under the hood, Cyter performs citation verification as part of the generation pipeline: after the initial response, it re-checks each footnoted citation against the retrieved source page. Unverifiable citations are flagged or removed before the response is returned to you.
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