Three kinds of inter-generational transfer are discussed. Despite the obvious advantages of partnerships and other forms of income splitting from the income tax viewpoint, about half of the primary producers in Australia continue to operate their businesses as sole traders. Some of the problems which arise with partnerships, trusts and companies in this regard are considered. The transfer of the ownership of the assets in addition to the ownership of the income stream they generate, is then considered in detail. The taxation of this transfer by means of gift and death duties raises many questions in relation to economic equity and efficiency. The third type of inter-generational transfer discussed in this paper is the transfer of the managerial role. Several suggestions are made which could help not only to reduce the family trauma which usually surrounds this issue, but which also could help reduce the tendency for farmers to hold the reins for too long.


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