Craig Marston explores the status of technical and practical implementation issues with the Attribution Managed Investment Trust Regime.
The Attribution Managed Investment Trust (AMIT) Regime has been with us now since May 2016 and it is therefore timely to consider where implementation is at. As many trusts race to elect-in for 2017-18, a number of interesting technical and practical implementation issues have emerged. These issues are challenging our understanding of the current MIT 'industry practice' and will shape the way trustees administer AMITs going forward.
In a paper I presented earlier this month for The Tax Institute (TTI), I explored some of these issues and set out the following key messages:
Despite some implementation uncertainties, there are several compelling 'carrots' and persausive 'sticks' to encourage electing-in to the AMIT Regime. In particular:
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