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: 0.1.8; 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

• 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. Specifically streamed capital gains and franked dividends are refused, not allocated: 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 7 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.
• 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 30 June Schedule Verifier: Checks timing, deed-power and percentage-completeness facts the caller supplies. The 3 deed and execution facts are True, False or unstated; an unstated one returns None for validity, naming the fact, rather than reporting compliance or a breach.

Quickstart

Installation

pip install solomons-sword

CLI usage

# Evaluate Section 100A risk zone
solomons-sword s100a-check --beneficiary "Adult Child" --amount 40000 --adult-child --retained-by-parents

# 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 --no-direct-benefit --no-commercial-loan

# 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.