LRBAs aren’t the only place for a bare trusts
Philippa Briglia, special counsel at Sladen Legal, said one of those is through absolute entitlement which is dealt with in TR2004/D25 and states that the “look-through” treatment of bare trusts in the context of the CGT provisions turns largely on the concept of "absolute entitlement". “There is a widespread taxpayer practice where bare trusts are not recognised for income tax purposes, that is the bare...
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