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原帖由 Poweregg 于 2012-7-2 08:44 发表 
谢谢熊猫积极参与讨论，辛苦了（稍后补分）
1，不明白你为什么要等到16W以上才算，其实到了3.7W以上，分配给oversea就不亏了
例如trust有8W收入
8W分给税务居民A，3.7万以上要交32.5%+1.5%medicare（2013税率），另外收入高了还会影响 ...
I am very boring today so I did a calculation base on your example figure.
The resident who has income 37K. and the trust has income of 80K.
All tax rate use 2013 rate.
Situation one: All trust income is franked dividend income
Dividend income 80K. Franking credit 34285.71 (80,000/7*3)
If resident:
Before distribution:
Total income 37000
Tax payable: 3572 (0.19*(37000-18200))
Medicare: 555 (37000*0.015)
Total tax payable 4127 (555+3572)
Low income offset: 455 (full amount if income under 37000)
Net tax payable: 3682 (4127-455)
All franked dividend income distributed from trust to this residentTotal income: 151285.71 (37000+80000+34285.71)
Tax payable: 43922.71 (17547+0.37*(151285.71-80000)
Medicare: 2269.29 (0.015*151285.71)
Total tax payable 46192.00 (43922.71+2269.29)
Refundable Franking credit:34285.71
Net tax payable: 11,906.29 (46192-34285.71)
While if total 80k all distribute to non resident
nothing will happen. They just get 80k and happily go oversea!
Because no withholding tax apply on fully franked dividend.
not even 30%. However,refundable franking credit of 34,285.71 is lost.
But what if you can find a resident who don't have income? for example your wife or your university kids?
Total income: 114285.70 (80000+34285.71)
tax payable: 30232.71 (17547+0.37*(114285.70-80000)
medicare levy: 1714.29
Total taxpayable: 31947
After Refundable credit avaliable: 34,285.71
Total refund: 2338.71~~~
That's the reason I normally don't advice to put non-residents as beneficiaries if you have other options. Income of 114,285.70 will be taxed at 37% tax rate but you still will get a refund because of the average tax rate is 27.95% and you still can benefit from the 30% franking credit.
Situation 2: If CGT all discounted and from selling australia rental property
Distribute all 80k discounted Capital gain to resident
Total income: 77000 (37000+80000*0.5)
tax payable: 16572
Medicare: 1155 (77000*0.015)
Total tax payable: 17727 (16572+1155)
While if distribute to non-resident:
The tax rate for non-resident at 2013 under 80k will be 32.5% (not 29% or 30%)
Total income: 80000 (no discount allowed)
Total taxpayable: 80000*0.325=26000
While if all the distribution income is interest or non-discounted capital gain (most likly from stock trading), then I agree that distribution to non-resident is a good option. Especially for the capital gain from the share trading, non-resident don't even need pay tax on this income because most shares are non-TAP asset 
So as I said it is really depend on what kind of income trust distributed. it is better to create a spreedsheet and test each options.
And also the tax rate for resident you have to count the fact that they have free tax threshold. therefore I always check the average tax rate (the net taxpayable/total income).
You will see in Situation one the resident who recieve 114,285.70 gross up dividend distribution from trust actually has a average tax rate of 7.87% while his income of 151,285.71 is in a 37% tax range.
And this calculation did not count the FTB effect. But if the taxpayer receive FBT, then it at least indicate he has a wife and some children. Whether any income can be distribute to those beneficiries will be another question need to be worked out. Franking credit is always better to keep in resident hand then lost on a non-resident's hand.
It is not as easy as 30% tax rate or not issue. I think a good tax accountant should consider all the possible options.
Anyway, I might be wrong >____<. I am still learning.
[ 本帖最后由 forevermary 于 2012-7-2 11:55 编辑 ] |
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爪子痒痒，再发回忆录 《二》（lilytop的毽球功） (2007-6-19) lilytop 
发表于 2012-7-1 22:50
