On 1 July 2016 Patrick Paul established the AKL discretionary trust ('the trust') for the benefit of two beneficiaries who are Australian tax residents, Ellen (is now 21 years old) and Sam (is now 17 years old). The trustee of the trust is James Conway.

During the year ended 30 June 2023, the receipts and outgoings for the trust were as follows:

Receipts

Franked dividend income

Dividend income (franked to 70%)

Income from unfranked dividends

Interest income

Rental income

$20,300

$18.000

$13,300

$2,000

$25,000

Outgoings

Rates and land tax on the trust's rental property

Deductible repairs to the trust's rental property

$5,800

$3,220

During the 2022/23 income year Ellen was presently entitled to and received $25,000 of net trust income. She also received net wages of $24,000 in the same income year, from which PAYG withholding of $2,870 had been deducted. Ellen does not have any private health insurance.

During the 2022/23 income year Sam was presently entitled to and received $12,500 of net trust income. Sam is a full-time student and in 2022/23 he received $10,500 from a part time sales job (no PAYG amounts were withheld from his Wages)