Trust distribution checks

Ryan Duguid is not a registered tax agent or BAS agent. Project support is limited to software issues reproduced with fabricated data. Do not send taxpayer information or request advice, return preparation, tax-treatment confirmation, or lodgement.

Project name Solomon's Sword. Distribution solomons-sword, import package louisgoldberg, command solomons-sword.

Trust distribution allocation, Section 100A / 99B risk evaluation, and Division 6 ITAA 1936 review helpers for Australian trusts.

Package lifecycle: published. Install solomons-sword from PyPI.

The australian-accounting repository contains the maintained source. The solomons-sword distribution and command match the project identity. The louisgoldberg import package remains unchanged, so internal Python imports do not need a rename.

In-repo version: 0.1.10; see release notes.

Named for the judgement of Solomon, where the threat of dividing the child in proportion is what reveals who the true claimant is. Division 6 allocates trust income by proportionate entitlement following Bamford; Section 100A asks who actually ended up with the benefit. The name is a tribute only.

Not advice

Nothing this engine produces is tax, legal or financial advice, an assessment or a determination. Outputs are review aids: confirm every allocation, zone and exemption against the current law, the trust deed and the entity's facts before acting, and leave lodgement decisions with a registered practitioner. Where the model does not implement a rule it refuses the input rather than returning a number it cannot stand behind.

Command output carries the beneficiary name you supply, because a workpaper line item is unusable without it. Treat that output as client data: write it to the firm's approved secure location, never to a path inside a repository.

Full boundary statement: DISCLAIMER.md.

What it checks

The Python calculation and validation functions accept boolean facts as True, False or None. Strings such as "False", numbers such as 0 and 1, and other types raise ValueError naming the field. None keeps its existing meaning: unknown where the model can report it, or a refusal where a stated fact is required.

• Division 6 Proportionate Allocation (Commissioner of Taxation v Bamford [2010] HCA 10): Calculates present entitlement proportions and allocates s 95(1) ITAA 1936 taxable net income and the franking credits that ride with it. Trust net capital gains and franked dividends are refused, not allocated, whether or not they are streamed: the Division 6E carve-out with Subdivision 115-C (including s 115-220) and Subdivision 207-B is not implemented, so a proportionate answer would be wrong. Non-resident beneficiaries (s 98(2A)/(3)), nil income of the trust estate and no presently entitled beneficiary (s 99 / s 99A) are refused for the same reason. Each beneficiary's residency is a required input and their legal disability is stated as True or False: those 2 facts select the refused paths, so an unstated one is refused rather than defaulted.
• Section 100A Reimbursement Agreement Matrix: Classifies supplied facts against ATO PCG 2022/2 as Green, Red, or outside those zones. The final guideline has white, green and red; the draft blue zone did not survive. White zone (income years ending before 1 July 2014) is out of scope because the function does not take an income year. Every fact is True, False or unstated, and the green zone turns on all 11 of them: while any is unstated the result is FACTS_NOT_ESTABLISHED, naming the facts that are missing, because an arrangement nobody has described is not one the ATO has said it will leave alone. An established red-zone trigger still returns RED. The red zone is the guideline's own scenarios, of which the engine models 2 (paragraph 34(a) and (b), and paragraph 36); parental retention in general and a corporate unpaid present entitlement without a loan keep an arrangement out of the green zone but are not red, and after Commissioner of Taxation v Bendel [2026] HCA 18 an unpaid entitlement is not by itself a Division 7A loan.
• Section 99B Foreign Trust Receipt Assessment: Computes assessable amounts under s 99B(1) after corpus exemptions (s 99B(2)(a)) and prior-taxed income. Residency during the year of income is a required input, stated with --resident-during-year or --not-resident-during-year, because s 99B(1) turns on it: an unstated residency is refused and a non-resident receipt is refused rather than assessed. The 3 exemption amounts default to nil, which gives the largest assessable amount, and the s 99B(2)(a) corpus add-back defaults to nil in the other direction, leaving the whole corpus exempt. The result carries one caveat naming each nil it relied on, in both directions, because a nil default cannot be told apart from a figure nobody supplied.
• Trust Resolution Schedule Verifier: Checks timing against 30 June or the deed's earlier deadline, deed-power and percentage-completeness facts the caller supplies. The deed and execution facts, including whether the resolution streams specific income and the deed's own deadline, are stated or unstated; an unstated one returns None for validity, naming the fact, rather than reporting compliance or a breach. Missing streaming powers are a defect only for a resolution that streams.

Quickstart

Installation

pip install solomons-sword

CLI usage

# Evaluate Section 100A risk zone
solomons-sword s100a-check --beneficiary "Adult Child" --amount 40000 --adult-child --pre-18-expenses

# Every fact stated, which is what a green zone needs. Each fact has a
# --no- form, and a fact left out is reported as not established.
solomons-sword s100a-check --beneficiary "Adult Child" --amount 40000 \
  --no-adult-child --no-retained-by-parents --no-circular --no-corporate-upe \
  --received-funds --within-two-years --no-direct-benefit --no-commercial-loan \
  --no-pre-18-expenses --no-retention-conditions --no-para-32-exclusion

# Assess Section 99B receipt from foreign trust with corpus deduction
solomons-sword s99b-check --beneficiary "Jane Doe" --gross 150000 --corpus 50000 --resident-during-year

Statutory sources and tests

All allocation and threshold algorithms use exact decimal.Decimal calculations to prevent rounding discrepancies in trust tax schedules.

Automated test suite

• Run the suite: pytest tests/
• The suite covers proportionate streaming, Section 100A zones the engine implements, Section 99B corpus deductions, and resolution gates. Do not treat a badge as a live coverage certificate.

Licence

MIT License. Created by Ryan Duguid.