Fletch Heinemann is one of the partners in Cooper Grace Ward’s tax team. He specialises in tax disputes and litigation. Fletch’s technical specialisations include income tax, GST, payroll tax and customs duties. In managing clients’ tax and customs disputes, Fletch helps with the audit stages, ATO interviews, notices of objection, appeals in the AAT, QCAT, Federal Court and Supreme Court. Fletch draws on this experience to provide upfront practical tax advice across a range of commercial issues.
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Individual Podcasts
Counting Down From 100: Is 99B the Next Sleeper to be Awakened?
Whilst section 100A was introduced into the Income Tax Assessment Act 1936 back in 1979, it would be fair to say it may have only become entrenched in some advisers’ minds in recent times. In that same year, section 99B relating to the receipt of trust income not previously subjec
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About the Podcast
Whilst section 100A was introduced into the Income Tax Assessment Act 1936 back in 1979, it would be fair to say it may have only become entrenched in some advisers’ minds in recent times. In that same year, section 99B relating to the receipt of trust income not previously subject to tax, was also introduced into the 1936 Act. Is this the next sleeper to catch advisers off guard, with a scope far broader than first realised? This session looks into finding out the answer, including:
- What type of income has the potential to attract section 99B?
- Is section 99C (interwoven with 99B) worded so broadly that advisers may be forgiven for saying “I didn’t see that coming”?
- The tax implications if section 99B applies, including the interest component (sec. 102AAM ITAA 1936)
- Does section 99B extend to proceeds from a CGT event involving units in a foreign managed investment trust, including whether it makes a difference if the units are “redeemed” or “sold”?
- Interaction with disregarded capital gains in foreign trusts (TD 2017/23, TD 2017/24)
- How do the rules apply to foreign deceased estates?
- Strategies to reduce the risk of section 99B applying
- Practical examples
Presented By

Fletch Heinemann
Partner, Cooper Grace Ward Lawyers Brisbane, QLDCPD Information
0.5 CPD hours
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