The 1884 Upton v Brown court case is of great importance in taxation. It involved Upton and Brown, beneficiaries of a discretionary trust, where one had income rights and the other controlled the trust's capital.

There are many s100A pain points - let's cover five in this update.

Let's go to the very start and look at trust income. Because we need to understand trust income before we can talk about trust losses.

The theory around foreign trusts is confusing. So in this episode let's use a New Zealand trust as a foreign trust example.

Foreign trusts are not an issue per se. Nor are resident trusts. It really depends. But if you do have a foreign trust, watch out for s99B ITAA 1936. That is a really dangerous one.

An asset protection trust (aka equity split) does not give you 100% protection but it helps. Each layer you use increases your protection from creditors.

Asset protection layers can get pierced through. None is watertight. But the more layers you have, the more protected you are.

Asset protection silos are to ringfence the assets of one business from the creditors of another.

Here are five transfer pricing examples that cover common transfer pricing issues.

A reasonably arguable position - a so-called 'RAP' - is essential to protect you from penalties and interest for incorrect transfer pricing.