Case W48

Members:
IR Thompson DP

Tribunal:
Administrative Appeals Tribunal

Decision date: 21 June 1989.

I.R. Thompson (Deputy President)

The applicant, F, is a company which was incorporated in June 1977, its objects including acting as a trustee. It is the trustee of two family trusts of a businessman, A. I shall refer to them as A's Family Trust No. 1 and A's Family Trust No. 2. The objection decision under review in these proceedings relates to an assessment made by the respondent on 23 January 1986 in respect of F as trustee of A's Family Trust No. 2 for the taxation year which ended on 30 June 1982. The assessment was made on the basis that F was liable to pay tax pursuant to the provisions of sec. 99A of the Income Tax Assessment Act 1936 (``the Act''). The amount of taxable income assessed was $35,152 and the tax assessed in respect of that taxable income was $21,091.20. F objected to the assessment. Its objection was totally disallowed by the respondent. On 18 June 1986 it requested that the objection decision be referred to a Taxation Board of Review for review. The objection decision had not been referred by the Commissioner to a Board of Review by 30 June 1986 when the Taxation Boards of Review were abolished and their jurisdiction was transferred to the Administrative Appeals Tribunal. Subsequently it was referred to the Tribunal pursuant to sec. 189 of the Act.

2. At the hearing of the reference the applicant was represented by Mr J.W. de Wijn, of counsel, and the respondent by Mr J.G. Larkins, of Her Majesty's counsel, and with him Mr G.A.A. Nettle, of counsel. Oral evidence was given by A and by two officers of the Australian Taxation Office who will be referred to respectively as X and Y. In addition to the small number of documents lodged under sec. 37 of the Administrative Appeals Tribunal Act 1975, numerous other documents were tendered in evidence. They included copies of the deeds of settlement of A's Family Trusts No. 1 and 2 and of two unit trusts established by A and his brother, B, who was engaged in business with him. Those unit trusts will be referred to as Unit Trusts No. 1 and 2. Among the documents were also copies of the income tax returns for the 1982 taxation year of A's Family Trusts No. 1 and 2, Unit Trusts No. 1 and 2 and a company, C, through which A and B publicly carried on their business. Finally, there were copies of various letters written by S, the accountant of A and B, photocopies of cheques, bank vouchers and bank statements and of a number of documents purporting to be acknowledgements by various persons of money having been distributed to them as beneficiaries from A's Family Trust No. 2 during the taxation year which ended on 30 June 1982 and to contain statements of agreement to lend that money back to the trust.

3. Finally, a number of documents were tendered by X setting out information derived from records supplied to the Australian Taxation Office by A, B and S. They included in particular a flow chart showing the movement of money between various entities during the 1982 taxation year purportedly evidenced by those records. Although X was cross-examined on a number of matters, it was not suggested to him, nor was evidence given by any other person to show, that the flow chart was inaccurate. Nor was it suggested or shown by any evidence that the other documents, which he had prepared, did not reflect accurately the records supplied to the Australian Taxation Office by A, B and S. In the course of the proceedings it was established that the trustee of Unit Trust No. 1 was a company, G, that the trustee of Unit Trust No. 2 was another company, H, and that a third Unit Trust had been established before the end of the 1982 taxation year with yet another company, J, as trustee. The flow chart shows that the business operations of C were connected with F through G. It shows also that just as A caused the establishment of his Family Trusts No. 1 and 2, B similarly caused the establishment of two Family Trusts bearing

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his name. The trustee of both was a company, E. Again the business operations of C were connected with E through G.

4. Because of the provisions of sec. 14ZK of the Taxation Administration Act 1953 letters of the alphabet have been used in this statement of reasons for decision so as not to disclose the identity of the persons referred to in it. In order to facilitate an understanding of this statement I have annexed to it a list of those letters and a description of the persons they represent.

5. In the 1982 taxation year there were two units in Unit Trust No. 1 One was held by F as trustee of A's Family Trust No. 1; the other was held by E as trustee of B's Family Trust No. 1. The income tax return in respect of Unit Trust No. 1 for the 1982 taxation year shows a net income of $69,876 and distribution to A's Family Trust No. 1 of 50% of that amount and to B's Family Trust No. 1 of the other 50%, that is to say, $34,938 is shown as having been distributed to each. As in Unit Trust No. 1, there were two units in Unit Trust No. 2, the one being held by F as trustee of A's Family Trust No. 1 and the other by E as trustee of B's Family Trust No. 1. The income tax return for Unit Trust No. 2 for the 1982 taxation year shows that, after the deduction of a loss of $5,521 carried forward from the previous year, the net income of the trust was $3,990 and that it was distributed as to 50% to A's Family Trust No. 1 and as to the other 50% to B's Family Trust No. 1; that is to say, $1,995 is shown as having been distributed to each of those trusts. Thus, the income of F as trustee of A's Family Trust No. 1 in the 1982 taxation year was $36,933; the income of E as trustee of B's Family Trust No. 1 was the same.

6. The deed of settlement of A's Family Trust No. 1 empowered the trustee to pay, apply or set aside all or any part of the net income of the trust fund for any one or more of the general beneficiaries. The general beneficiaries were defined in cl. 1 as including the trustees of any trust in which any person who was a specified beneficiary had a share or interest, whether vested or contingent. At all relevant times A was one of the specified beneficiaries. The deed of settlement of A's Family Trust No. 2 empowered the trustee to pay, apply or set aside the net income of the trust fund to or for the benefit of, inter alia, any one or more of the beneficiaries who constituted the secondary beneficiary. The secondary beneficiary was defined in cl. 1 as including the children of the beneficiaries who constituted the primary beneficiary. The primary beneficiary was defined as meaning the person or persons so described in the schedule; in the schedule both A's parents were included among those constituting the primary beneficiary. Consequently in 1982 F as trustee of A's Family Trust No. 2 was one of the general beneficiaries of A's Family Trust No. 1.

7. The income tax return of A's Family Trust No. 1 for the 1982 taxation year shows that its net income was $36,617. Annexed to that return and lodged as part of it was a copy of the minutes of a meeting of the directors of F purportedly held on 29 June 1982 at which it was purportedly resolved that the taxable income of A's Family Trust No. 1 was to be distributed as to 7% of the income to A and B's wife and as to 93% of the income to A's Family Trust No. 2. The income tax return for the 1982 taxation year of A's Family Trust No. 2 shows a net income of $35,152. It shows also a distribution of amounts of $4,000 to eight persons included within the definition of the secondary beneficiary of that trust and an amount of $3,152 to a ninth such person, thereby accounting for the whole of the net income. As in the case of the income tax return of A's Family Trust No. 1, annexed to the return and lodged with it was a copy of the minutes of a purported meeting of directors of F on 29 June 1982 at which a resolution was purportedly passed which provided for the distribution shown in the return.

8. At the commencement of the hearing Mr de Wijn informed the Tribunal that the purported resolution of which a copy was annexed to the income tax return of A's Family Trust No. 2 was invalid. One of the two persons, S, who had attended purportedly as a director of F had in fact ceased to be a director on 28 June 1982. The invalidity of the resolution and the purported distribution was not disputed by Mr Larkins and the case thereafter was argued on that basis. Neither counsel drew attention to the fact that the resolution of the directors of F as trustee of A's Family Trust No. 1 was apparently also invalid for precisely the same reason. Why they did not do so is not clear. However, Mr de Wijn did not seek to have the grounds of the objection amended to include an assertion that the net

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income of A's Family Trust No. 2 was not $35,152, as shown in the return. That being so, although the Tribunal has power under sec. 190 of the Act to order that the taxpayer not be limited to the grounds stated in its objection, it would not be appropriate for me to make such an order. The hearing was conducted by Mr de Wijn on the basis that A's Family Trust No. 2 had net income of $35,152 and, I am satisfied, the review should proceed on that basis. That does not, of course, preclude the respondent from making at some future date an amended assessment in respect of A's Family Trust No. 1 or of its default beneficiaries if there was no valid distribution to A's Family Trust No. 2 and if the amendment is otherwise permitted by sec. 170 of the Act.

9. The evidence establishes that the applicant was not born in Australia. He lived with his parents in the country of his birth until he was nearly 18 years old. When he came to Australia he left his parents behind, and also some uncles and aunts with whom he and his parents had maintained close ties. They resided in a village; their standard of living was very low by Australian standards. His older sister and older brother had emigrated to Australia before him and had obtained a loan from a bank to pay his fare to come here. Before coming to Australia he had been trained as a carpenter. In Australia he worked at that trade and subsequently began his own business utilising his trade skills. Soon after he had come B also came. When A started his business, he did so together with B. The business prospered and they carried it on publicly throughout the 1982 taxation year through their company C.

10. A gave evidence that, soon after he had begun to earn money in Australia, he had sent some to his parents and his aunts and uncles in the country of his birth. In 1977 S had suggested to him that he should establish a trust fund and channel his beneficence to his parents and other relatives through that fund. As a result his Family Trust No. 1 had been established. F, which had been incorporated shortly before, had been established or acquired so that it could be the trustee of that trust. In the deed of settlement the specified beneficiaries were stated as being A and his children, although at that time he was unmarried and had no children. Included among the general beneficiaries were his parents, two aunts and two uncles; the applicant said that they were uncles and aunts with whom his parents had maintained a close tie.

11. However, it seems that his advisers did not alert him to the provisions of reg. 8 of the Banking (Foreign Exchange) Regulations (subsequently repealed) or the Reserve Bank's view that its authority was required for the establishment of a trust with overseas beneficiaries. A gave evidence that it was not until 1981 that S drew those matters to his attention; he said that it was in consequence of learning of them that he arranged for the establishment of his Family Trust No. 2. The deed of settlement of that trust was executed on 4 June 1981 with S's wife as the settlor and F as the trustee. The persons constituting the primary beneficiary were A's parents and the two uncles. As already noted, A was included among the persons comprising the secondary beneficiary but only in terms of his being a child of one of the persons constituting the primary beneficiary. The other persons who constituted the secondary beneficiary were the brothers, sisters, spouses and children of any of those persons, other persons in any way bearing a blood relationship to any such person and any other persons, excluding the settlor and the trustee, appointed by the trustee, whether bearing a blood relationship to any of those persons or not.

12. The deed of settlement of each of A's two family trusts conferred on F as trustee a discretion to distribute the net income of the trust to any one or more of its beneficiaries. Similarly each contained provision for the situation where the trustee did not exercise that discretion within any taxation year (described in the deeds as ``the Accounting Period'') so as to exhaust that year's net income. The net income, or the balance of it remaining, was to be held by F in trust for certain beneficiaries. The default beneficiaries were to be, in the case of A's Family Trust No. 1, the specified beneficiaries and, in the case of A's Family Trust No. 2, the persons constituting the primary beneficiary. As A and his children were the specified beneficiaries of his Family Trust No. 1 and his parents and uncles constituted the primary beneficiary of his Family Trust No. 2, the default provisions of the one were to have significantly different results from the default provisions of the other.

13. Asked why in 1981 he had not created the second family trust in the same terms as the

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first, A said that it was because he had intended to benefit his parents and his uncles and thereby to relieve their property. However, although over the years from 1978 onwards F, initially as trustee of A's Family Trust No. 1 and latterly as trustee of A's Family Trust No. 2, purportedly distributed income of the trust funds to the uncles and the aunts and to a number of other beneficiaries who were also resident outside Australia, it did not purport to distribute any of the trust funds to A's mother until the 1983 taxation year and it never purported to distribute any to his father. Further, although it purported to distribute amounts in excess of $22,000, $49,000, $41,000, $10,000 and $35,000 respectively in successive years beginning with the 1978 taxation year, no money was remitted during those years to any of the beneficiaries to whom the distributions were purportedly made. Money was remitted to A's parents between October 1977 and 30 June 1982, but by A and B, not by F. In the 1978 taxation year a total of $500 was remitted, in the 1979 taxation year $1,300, in the 1980 taxation year $550 and in the 1981 taxation year $450. In the 1982 taxation year no amount was remitted. During the 1979, 1980 and 1981 taxation years money totalling $1,771.04 was also remitted by A and B to a relative resident in Canada. That relative was one of the beneficiaries to whom a distribution was purportedly made from A's Family Trust No. 2 in the 1982 taxation year; but no money was remitted to him in that year. No money has ever been remitted to either of the two uncles by A, B or F, even though in some of the taxation years before the 1982 year amounts were purportedly distributed to them by F.

14. A gave evidence that the reason why no money was paid to any of the beneficiaries to whom income of his family trusts was purportedly distributed was that they lent the money back to F straight away for the purpose of reinvestment by A and B in their business and in property. He was unable to say whether any of those loans were made at interest and, if so, at what rates of interest. He tendered documents apparently signed by five of the beneficiaries to whom income of his Family Trust No. 2 was purportedly distributed in the 1982 taxation years as the result of the purported resolution of F's directors on 29 June 1982. In those documents each of the beneficiaries appears to acknowledge having been advised and being aware of the distribution of $4,000 to him or her by the trust; each appears also to agree to lend that amount to the trust. A said that he had obtained the signatures of those beneficiaries on those documents during a visit to his country of birth earlier this year; while there he had received a message from B that it was desirable to obtain for the purpose of these proceedings documentary proof of the distribution and of the loans. He did not suggest that previously the beneficiaries had signed any written acknowledgements of distributions or any written agreements to lend back moneys distributed.

15. However, he said, over the years he had communicated with the beneficiaries. He acknowledged that he had not always done so directly and that sometimes it had been through his mother. But he said that they had been made aware of the distributions to them and had been agreeable to the money being retained as a loan and reinvested in his and B's business and in property. Asked why, if the object of his beneficence was to alleviate the poverty of the beneficiaries, money had not been remitted to them, he said that not all of them were poor and that reinvestment of the money would benefit them more in the long term. Pressed on the question whether he had obtained the agreement of every beneficiary on every occasion before retaining the money and treating it as a loan, he admitted that he had effectively made the decisions to retain the money as loans on his own initiative, although he said that there had been general consultation with beneficiaries.

16. He gave no satisfactory explanation why, if his reason for establishing the trusts was his concern about his parents' poverty, no money was distributed to his mother before the 1983 taxation year or to his father at all. Asked by Mr Nettle how the amount to be distributed to each of the beneficiaries in each of the years had been decided upon, he said that it had depended on the total amount available for distribution and the number of beneficiaries whom he had wished to benefit. He denied that there was any significance in the fact that the amount of $4,000 which it was decided to distribute to eight of the beneficiaries in the 1982 taxation year was the maximum amount of Australian income that could be received by a person overseas without liability to pay

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Australian income tax. He denied further that the very much smaller amount of $585 distributed to 14 beneficiaries in the 1983 taxation year was decided upon because for that year the tax-free threshold for persons overseas had been reduced to that figure. I find totally incredible his evidence of how beneficiaries were selected and why particular amounts were decided upon for distribution to the individual beneficiaries selected.

17. The flow chart prepared by X shows that both in respect of A's family trusts and B's family trusts there was a ``round robin'' of book entry payments between G, F, E and the beneficiaries to whom the income of A's Family Trust No. 2 and B's Family Trust No. 2 was purportedly distributed. The chart shows $34,938 as distributed by G as trustee of Unit Trust No. 1 to each of F and E as trustees of A's Family Trust No. 1 and B's Family Trust No. 1 respectively. Then after the purported distributions of the income of those trusts to the beneficiaries and the purported loans back to F and E by those beneficiaries, $34,938 is shown as paid back by each of F and E to G as trustee of Unit Trust No. 1. X gave evidence which further emphasised the artificiality of the transactions, namely that in G's journal the payment out of the two amounts of $34,938 was recorded on the same date as the receipts of two amounts of $34,938. X gave further evidence, which was not challenged in cross-examination nor rebutted by any other evidence, that no records had been made available by A, B, S or any other adviser of A or B to the Australian Taxation Office recording in any ledger or in any ledger system the alleged loans by the beneficiaries or showing any interest to which they might have been entitled.

18. I have already recorded my finding that A's evidence in respect of certain matters was not credible. I have noted that he gave no satisfactory answers to certain questions put to him by Mr Nettle. I do not accept that he intended, in effect, to give away all the income from his business to relations to whom he had no particular obligation and some of whom were not living in poverty so as to need such exceptional beneficence. I do not believe his evidence that the persons to whom distributions from his Family Trust No. 2 were purportedly made were aware that they were beneficiaries or that distributions had been made to them. Although the signatures may well be genuine, the five documents contain no clear statement of understanding by the signatories of the existence of the trust or of their beneficial interest in it. They were not notarised or even witnessed by an independent person. They contain no certificate as to any translation which may have been necessary for the signatories' understanding of the contents and indeed, since four of them are signed in the alphabetic script of their country (the other signature being indecipherable), such translation was almost certainly needed. A's own evidence of his discussions with them cannot, I am satisfied, be relied on. Having regard also to X's evidence and to the flow chart prepared by him, I reject as untrue A's evidence of distribution of the trust's income to beneficiaries and loans back by them.

19. I also reject as untrue his evidence that his object in causing the establishment of his Family Trust No. 2 was to benefit his parents and his uncles. If that had been his object, he would have caused a valid resolution to be passed by the directors of F for some or all of the income of the trust to be distributed to them. The money would then have been sent to them. Instead, he took part in a purported meeting of the directors on 29 June at which a resolution was passed to distribute all the income to other relations. I find it impossible to believe that he and S were not aware that S had ceased to be a director of F on the previous day, so that the purported resolution was invalid.

20. I have no doubt that A's object in causing his Family Trust No. 2 to be established was to obtain tax advantages and that he established it after receiving advice from S. The history from 1978 onwards of bogus distributions from A's Family Trust No. 1 with purported loans back, and the terms of the resolution invalidly passed in June 1982 for the distribution of the 1982 income of A's Family Trust No. 2, leave me in no doubt that, when that second family trust was established, A intended to utilise it to deceive the respondent. The only inference which, I believe, can reasonably be drawn from the events which occurred and the context in which they occurred is that, when A and S passed the purported resolution on 29 June 1982 for a similar bogus distribution, they hoped that there would be no investigation into the purported

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distribution; but, in case the respondent alleged that it was a sham as it undoubtedly would have been if they had both been directors of F when they passed the resolution, they were deliberately reserving what they believed to be a trump card, namely their ability to show, as has been done in these proceedings, that the purported distribution was invalid and then to rely on the default distribution provisions of the deed of settlement.

21. What remains to be determined is what, so far as F's liability to taxation under sec. 99 or 99A of the Act is concerned, are the legal consequences of what was done. Mr Larkins submitted that the provisions of A's Family Trust No. 2 relating to the default distribution of its income were a sham. Although in a written statement of the facts and contentions lodged with the Tribunal, on its directions, before the hearing, the respondent asserted that the establishment of the trust itself was a sham, he expressly disavowed that assertion. In the alternative he argued that the provisions of Pt IVA of the Act were applicable, with F as trustee of A's Family Trust No. 2 as the relevant taxpayer benefited by a scheme. Mr de Wijn submitted that, if there was a sham, which he denied, the whole of the deed of settlement of A's Family Trust No. 2 must be a sham, so that F never became trustee of any such trust and, therefore, could not be a taxpayer in that capacity. So far as Pt IVA of the Act was concerned, he submitted that, if there was a scheme as defined in sec. 177A, which he denied, the taxpayer who obtained a tax benefit in connection with it was not F as trustee of A's Family Trust No. 2 but C or G. He asserted that A's Family Trust No. 2 was a valid trust and that by reason of its terms, when the invalid distribution purported to have been made in accordance with the resolution of 29 June 1982 failed, there was a distribution to the default beneficiaries. Accordingly, neither of sec. 99 and 99A imposed any tax liability on the trustee. Any such liability lay on the persons who constituted the primary beneficiary.

22. In
Scott v. Commr of Taxation of the Commonwealth (No. 2) (1966) 40 A.L.J.R. 265 at p. 279 Windeyer J. discussed the nature of ``sham'' in relation to schemes to avoid or minimise liability to taxation. He said:

``but it is not enough to say that a fund governed by the provisions of a deed such as that we have here could be a superannuation fund within the meaning of the Act. For it to be so in fact the parties concerned must have intended that the deed should take effect and operate according to its tenor; that a fund should be set up subjected to the trusts of the deed; and that Associated Provident Funds should as trustee be bound to carry out those trusts. On the other hand, if the scheme, including the deed, was intended to be a mere facade behind which activities might be carried on which were not to be really directed to the stated purposes but to other ends, then the words of the deed should be disregarded. It was urged for the appellant Associated Provident Funds that it is a real company and that the deed was really executed by it; and that, it was said, is the end of the question. But it is not. A disguise is a real thing: it may be an elaborate and carefully prepared thing; but it is nevertheless a disguise. The difficult and debatable philosophic questions of the meaning and relationship of reality, substance and form are for the purposes of our law generally resolved by asking did the parties who entered into the ostensible transaction mean it to be in truth their transaction, or did they mean it to be, and in fact use it as, merely a disguise, a facade, a sham, a false front - all these words have been metaphorically used - concealing their real transaction...''

23. In the following year Diplock L.J. said in
Snook v. London and West Riding Investments Ltd. (1967) 2 Q.B. 786 at p. 802:

``As regards the contention of the plaintiff that the transactions between himself, Auto Finance and the defendants were a `sham', it is, I think, necessary to consider what, if any, legal concept is involved in the use of this popular and pejorative word. I apprehend that, if it has any meaning in law, it means acts done or documents executed by the parties to the `sham' which are intended by them to give to third parties or to the court the appearance of creating between the parties legal rights and obligations different from the actual legal rights and obligations (if any) which the parties intend to create. But one thing, I think, is clear in legal principle, morality and the authorities (see Yorkshire Railway

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Wagon Co. v. Maclure (1882) 21 Ch.D. 309, C.A. and
Stoneleigh Finance Ltd. v. Phillips (1965) 2 Q.B. 537), that for acts or documents to be a `sham', with whatever legal consequences follow from this, all the parties thereto must have a common intention that the acts or documents are not to create the legal rights and obligations which they give the appearance of creating. No unexpressed intentions of a `shammer' affect the rights of a party whom he deceived. There is an express finding in this case that the defendants were not parties to the alleged `sham'. So this contention fails.''

24. I have no doubt that neither A nor S's wife as settlor of A's Family Trust No. 2 intended that the persons constituting the primary beneficiary of the trust should be entitled to have any part of the income of the trust distributed to them in default of the exercise by the trustee of its discretion. I am satisfied that they did not intend there to be any real distribution of the income of the trust to anyone other than A and possibly his children. I find that A meant to utilise the discretionary distribution provisions of the deed of settlement to cloak the real transactions which he intended to undertake, and that he meant the default distribution provision, if it ever purportedly took effect, similarly to disguise the real situation.

25. I have come to the conclusion, therefore, that the provision of the deed of settlement of A's Family Trust No. 2 for default distribution to the primary beneficiary was a sham, that is to say that it was never intended to create legal or equitable rights or obligations. It was never intended that, if there were no distribution to any other beneficiary in accordance with the terms of the deed of settlement, there should be a real distribution to persons constituting the primary beneficiary. By contrast, however, although A undoubtedly intended that bogus use should be made of the discretionary power of distribution to the secondary beneficiary, that power could be exercised in favour of himself and his children and also in favour of B and his children and might at some time in the future have been genuinely so exercised. I have come to the conclusion, therefore, that the provision of the deed of settlement conferring that discretionary power on the trustee was intended to be available to be validly exercised if and when it became advantageous to exercise it so. Its inclusion in the deed was, therefore, not a sham.

26. I do not accept as correct Mr de Wijn's submission that, if any provision of the deed of settlement was a sham, the whole deed must be a sham. A trust is not rendered void simply by the fact that some of its provisions are void (
Re Mill's Declaration of Trust; Midland Bank Executor & Trustee Co. Ltd. v. Mill and Ors (1950) 1 All E.R. 789). An analogy may, I believe, properly be drawn between a provision of a trust deed which is void and one which is inoperative by reason that it is a sham. Further, a trust is not rendered void by the fact that the settlor was actuated by an illegal motive or created the trust for an illegal consideration (
Ayerst v. Jenkins (1873) 16 L.R.Eq. 275), at least where that would simply benefit the person who created the trust. I have, therefore, come to the conclusion that A's Family Trust No. 2 was validly created and validly existed during the 1982 taxation year, and that there was no valid distribution of any of its income in that year either as the result of the exercise of any discretion by the trustee or as the result of any of the terms of the deed of settlement taking effect in default of the exercise of such a discretion. Consequently, sec. 99A of the Act was applicable.

27. As I have come to the conclusion that the purported distribution of the trust's income as shown in the income tax return of F as trustee of A's Family Trust No. 2 was invalid and the provision of the deed of settlement for default distribution a sham, it is unnecessary, and it would be inappropriate, for me to consider the Pt IVA arguments. The objection decision under review must be affirmed.

Annexure: dramatis personae

JUD/89ATC460 history
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