• General overview of trusts:
o What is a trust
o What is it used for
o How is it created
o How is it managed
o What types of trusts are there (from both a legal and tax perspective)
o How is its tax residency determined
• Income Tax and CGT: General
o Overview on the interaction between the standard rules (Section 25B and
paragraph 80 of the Eighth Schedule) and the attribution rules (Section
7)
o The impact of these provisions on multi-layered trust structures
• Income Tax and CGT: Specific (Section 25B and paragraph 80 of the
Eighth Schedule: who is taxed on what kind of income, which deductions
are allowed and for whom, how are capital gains taxed)
o Resident trusts
o Non-resident trusts
o Resident beneficiaries (including anti-avoidance rules on capital
distributions from non-resident trusts)
o Non-resident beneficiaries (including recent Budget proposals on the
changes coming to Section 25B)
• Income Tax and CGT: The attribution rules (Section 7 and the Eighth
Schedule)
• Income Tax and Donations Tax: Loans with connected trusts (Section 7C)
• Things to look out for with trust distributions and trust deeds