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Is it the beginning of the end for discretionary trusts and one-man companies - Centrelink, Bankruptcy and Taxation

Date: September 01, 2010

Authors: Michael Pickering B.A., LL.B. (Hons.), LL.M., M. A.

Another example is Elliott v. The Secretary of the Department of Education, Employment and Workplace Relations decided in 2008 immediately before the High Court of Australia’s decision in Spry and was concerned with the means test for Centrelink pensions. 

The “controlled trust” provisions in the Social Security Act 1991 (Cth.) were held to aggregate the interests of controllers in underlying discretionary trust assets for the purposes of pension entitlements. In other words, this is another example where control is equated to power which is equated to property interests.  

Another statutory use of “powers” is section 58 of the Bankruptcy Act 1966 (Cth.) which defines the extent of “property” which goes to a bankrupt’s creditors.   Such property is expressly defined to include “powers” which the bankrupt could exercise before he or she became bankrupt. Upon the reasoning of the Westpoint and Spry decisions, a bankrupt’s divisible assets may well include the assets of discretionary trusts they control even if those trusts were set up well before the maximum claw back powers which trustees in bankruptcy would be able to exercise.   This would mean that the assets of discretionary trusts controlled by persons with effective unchecked rights of appointment may be available in bankruptcy regardless of whether or not the controller is eligible to benefit himself or herself.   If such a legal development were to occur within bankruptcy law,  there would need to be urgent statutory safeguards for the assets of trusts for charitable or sporting purposes where the trustees were bankrupted.   Otherwise, trustees could well have massive assets deemed to be their property where they do not “own” those assets in any normal way.

The most important effect of the changing laws on discretionary trusts will be in the tax area.   The Commissioner of Taxation may be able to use the reasoning in the above Federal Court and High Court authorities to argue that discretionary trusts which are controlled by single appointors or trustees are no longer effective vehicles to split income and that the corpus or income should be properly regarded as that of the controlling figure.   Such a conclusion could have dramatic effects upon future income tax and capital gains tax liabilities for taxpayers who, for decades, have assumed that their discretionary trusts were effective lawful taxation minimization vehicles.  

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