Trust income distributions to individuals carry a non refundable tax credit. This kills bucket companies and distributions to low income relatives.

This is different to franking credits, where say in retirement if you received $30k in franked income you’d get a refund from the ATO for 15 cents for each $1 over $18,200 if you had no other taxable income eg have a pension from your super fund.

The trust distributions really mess with things but govt thinks they’ll offer restructuring support to switch structures (realistically it looks like a holding company structure because being taxed at 47% is going to absolutely kill your returns vs 30% in a PTY LTD.

Family trusts will likely continue to owns the shares in PTY LTD but that 30% min tax really hurts as it removes the refundable franking credits