This article examines the following question posed by Hill J in Liedig v FCT: is there a principle of tax law which holds that a trustee in receipt of income from his personal exertion must be deemed to derive that income beneficially so that he is not protected from personal assessment by s 96 of the Income Tax Assessment Act? In line with his Honour's finding, it is contended that there is no clear support for this principle in the authorities.
"Liedig and the Limits of Section 96,"
Revenue Law Journal:
1, Article 6.
Available at: http://epublications.bond.edu.au/rlj/vol8/iss1/6