Budget 08

Changes to Family Trusts show lack of understanding

In Budget 08, the new Federal Government introduced changes to legislation governing Family Trusts which apply from 1 July 2008. One of these changes focuses on limiting the ability of family trusts to distribute income.

According to Scott Arnold, partner of Walker Wayland NSW, the changes reflect a lack of understanding at the Federal Government level of how family trusts operate.

“Unfortunately this lack of understanding at the Federal level comes down to a wrong perception of family trusts which is also common in the broader community too,” says Scott.

“Essentially, this perception asserts that family trusts are the preserve of the rich and wealthy and are used only as a mechanism to avoid tax.

“In reality, family trusts are a legitimate vehicle through which assets and investments of a family group can be held for the benefit of the entire family.

“Rather than give assets to individuals, all assets including investments are pooled, with the income from this pool used to support the family group,” Scott says.

Essentially, the budget changes relate to reversing two provisions:

  • the ability for family trusts to reduce income tax has been reduced by limiting their ability to offset old losses. This is expected by the Government to claw back tax of approximately $24 million
  • the definition of “family” in the family trust election rules has been changed to limit descendants to children or grand children of nominated beneficiaries. Previously, “family” also included nephews, nieces and their spouses. This change places greater emphasis on who is named as the nominated individual in family trust elections. Distributions to people who are not descendants of this nominated individual under the changed ‘family’ definition will be taxed at a higher rate

This second change has significant consequences:

  • It makes the choice of a nominated individual even more critical, potentially requiring the nomination of one sibling over another
  • Income from assets accumulated in old family trusts cannot pass through to great-grandchildren without being subject to family distributions tax
  • The limitation to grandchildren could shorten the life of a trust as family groups decide to wind-up the trust and pay the tax in order to pass on the benefits beyond the restricted family group

Under a further restriction also applying from 1 July 2008, family trusts will be prevented from making a one-off variation to the nominated individual specified in the family trust election except in the case of marriage breakdowns.

According to Scott, the usefulness of family trusts in building assets was emphasised following a change to tax deductible super contributions as this reaffirmed family trusts offered a viable, alternative investment structure.

“Last year, changes to tax deductible super contributions for people aged under 50 reduced the amount of contributions from $105,000 to $50,000,” Scott says.

“By investing this money in a family trust instead, people maintain access to their money at all times rather than locking this away in a super fund which they can only access after 65, or after satisfying another condition of release.

“It’s important to emphasise that as with any other tax strategy, there must be a viable commercial or wealth creation reason for establishing a family trust otherwise people are playing right into those perceptions of tax avoidance,” he said.

People concerned about this issue should contact their local Walker Wayland business adviser or contact Scott Arnold at Walker Wayland NSW.

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