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Courses/Business, Commercial & Financial Law/Tax, Bankruptcy & Consumer Law

Tax Planning Strategies for High Net Worth Clients

Master advanced wealth preservation, strategic estate structuring, and proactive tax mitigation frameworks tailored to maximize and protect multi-generational wealth.

Created byPeter Azam
BeginnerUpdated Sep 8, 2026
Tax Planning Strategies for High Net Worth Clients

What You'll Learn

check_circleAssess key developments affecting contemporary Australian tax planning
check_circleIdentify risks arising from trusts, Division 7A, and Section 100A
check_circleEvaluate asset protection, succession, and CGT planning strategies
check_circleApply practical documentation and risk-management approaches for ATO scrutiny

About This Course

Tax planning for high-net-worth Australian clients is undergoing significant change as intensified ATO scrutiny, judicial developments, and proposed reforms reshape the way practitioners approach trusts, succession, asset protection, and wealth structuring. This practical course provides an advisory-focused framework for navigating these developments, with particular attention to the Bendel decision, Section 100A, Division 7A, discretionary trusts, and evolving ATO compliance expectations. Participants will explore how recent tax developments affect real-world structuring and advisory decisions, while gaining practical strategies for managing risk, strengthening documentation, and developing robust tax planning approaches for private groups and high-net-worth families.

Key Topics Discussed:

  • ATO areas of focus 2025–26 for private groups (CGT, trusts, Division 7A, succession planning)
  • Tax residency tests for individuals (resides test, domicile, 183-day, superannuation tests)
  • Residency and CGT — becoming/ceasing Australian tax residency, TAP and main residence exemption
  • Deceased estates and trust taxation (Division 6 of ITAA 1936, sections 95/97/99/99A)
  • Tax-free threshold treatment for deceased estates and testamentary trusts (section 102AG)
  • Section 99B and foreign trust distributions, including the corpus exception
  • CGT and deceased estates under Division 128 (and its exceptions — CGT event K3, main residence, philanthropic gifts)
  • CGT and testamentary trusts (CGT events E5–E7)
  • Superannuation death benefits (SIS vs tax dependents) and planning tips (EPOA, super death benefit trusts)
  • Present entitlement principles (Harmer v FCT, FCT v Carter)
  • Section 100A and PCG 2022/2 risk zones (white/green/red)
  • Division 7A — deemed dividends, exceptions, and compliant loans
  • Commissioner of Taxation v Bendel [2026] HCA 18 and its impact on UPEs
  • Family trust elections, interposed entity elections, and the family group test
  • Trust loss rules (control test, pattern of distributions, Schedule 2F)
  • Business restructuring: incorporation rollover (Subdiv 122-A/B) and small business restructure rollover
  • Division 152 small business CGT concessions
  • Proposed 30% minimum trust tax (from 1 July 2028) and its strategic implications
  • Advisory considerations and discussion points for responding to the proposed trust tax reform before 2028

Your Instructor

Peter Azam
Peter Azam

Senior Associate, Corporate & Commercial | Coulter Legal

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Peter joined Coulter Legal in July 2026 as Senior Associate specialising in taxation, structuring and succession planning, with a particular focus on small and medium enterprises, high net worth individuals and family groups, and their related international structures. His experience extends to corporate transactions and advisory work, including mergers and acquisitions. Peter regularly advises clients on tax-effective business structuring, asset protection, and intergenerational wealth transfer, helping families and business owners navigate the complex interplay between commercial objectives and taxation and legal obligations. He brings a practical, commercially minded approach to his advice, drawing on both his legal expertise and his deep understanding of the taxation issues that affect growing and established businesses alike. In addition to his legal practice, Peter is an active contributor to legal education. He holds a Master of Laws from the University of Melbourne, specialising in taxation law, and currently serves as an adjunct lecturer in higher education, teaching Taxation Law, Company Law, and Trusts and Equity. This dual role as practitioner and educator keeps Peter at the forefront of legal and regulatory developments, ensuring his advice reflects both technical rigour and real-world commercial relevance.

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We are a registered provider with 327+ associations and regulatory bodies worldwide. We operate across 29 global markets including Canada, the US, Australia, and the UK. Every course page clearly displays its specific accreditations. Upon completion, you receive a professional certificate that can be validated online. Our certificates include all necessary accreditation details, credit hours, and completion dates, and are formatted specifically to meet the submission requirements of most global regulatory bodies.

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