The correct allocation of tax liability under a trust is determined by reference to the beneficiary’s ‘present entitlement’ to the income of the trust. It is apparent that the equitable nature of the parties’ interests, under a trust, has made the determination of tax liability difficult. In order to clarify the position, this article will outline the equitable principles referred to in case law.
"An Analysis of the Concepts of 'Present Entitlement',"
Revenue Law Journal:
1, Article 9.
Available at: http://epublications.bond.edu.au/rlj/vol13/iss1/9