While not thinking about the accounting fees per year, would anyone thing the process will be good. Lets just say the HDT has no units issued (so it operates as a normal DT) A DT owns shares and is +ive geared, it then distributes this to a company at the end of the year (only franked and undisccounted gains, discounted gains go direct to an individual, or the negative geared trust). The company is owned by another negative geared trust. The company can then distribute to the negative geared trust (via distributions) to offset the negative geared. The only catch here is it would have to distruibute enough gains to the negative geared trust so it could distribute the franking credits out. Alternatively if i dont have enough in the company to distribute for the -ive trust to become +ive, i would just not distribute that year. Any flaws in the system? Could the hdt and Dt have the same corp trustee?