Non-binding edited private advice. This is an edited version of private advice the ATO gave to a specific taxpayer about their own circumstances. You cannot rely on it — it is not binding and provides no protection for anyone else (see PS LA 2008/4). Use it as a guide to the ATO’s thinking, not as authority.
Will the ownership of the chattels (as detailed in the relevant agreements and set out in the facts and circumstances of the Ruling) by the Sub Trusts result in Trust A being a 'trading trust' within the meaning of section 102N of the
Income Tax Assessment Act 1936
(ITAA 1936)?