Investment Structure

I am considering a structure for a townhouse development project in Queensland. The land is to be purchased in the name of the structure, townhouse built and after completion each investor will have designated townhouses transferred into his/her entity.Prior to the initial purchase of the property  the co-owners would enter into a deed whereby they acknowledge that the land is to be held on bare trust for the benefit of each other in accordance with the proposed plan of subdivision each co-owner will hold their interest in the other co-owners post-partition lot on bare trust for that other co-owner. That is, the land is legally registered in the names of all co-owners as tenants in common in each shares but the each co-owner holds their interest in one post-partition lot absolutely and the balance of that post-partition is held for the benefit on bare trust by the other co-owner(s).

For example, the deed would give effect to the following ownership structure prior to the acquisition of the property:

____________________________________________________________________________________________

Post-partition                                   Post-partition                                Post-partition

    Lot 1                                                 Lot 2                                                 Lot 3

    Co-owner 1:                                     Co-owner 2:                                     Co-owner 3:

    Legally & beneficially owns 1/3        Legally & beneficially owns 1/3        Legally & beneficially owns 1/3

    1/3 held by co-owner 2                     1/3 held by co-owner 1                    1/3 held by co-owner 1

    1/3 held by co-owner 3                     1/3 held by co-owner 3                    1/3 held by co-owner 2

____________________________________________________________________________________________

After partitioning:

____________________________________________________________________________________________

     Lot 1                                                 Lot 2                                                 Lot 3

     Co-owner 1                                     Co-owner 2                                     Co-owner 3

____________________________________________________________________________________________

As I understand the beneficiary for whom the interest(s) are held on bare trust is treated as the owner of the asset and is considered to own the interest from the time the property was acquired.

As I understand there should not be any tax consequences on the partitioning. This includes no stamp duty in Queensland.

It should be noted that the Bare Trusts are not as simple as Bare Trusts used for SMSF, where they hold only one property. The Bare Trusts in this case hold 1/3 of a lot for the Co-owner 1, 1/3 for the Co-owner 2 and 1/3 for the Co-owner 3.

I  am wondering whether anybody has any experience with this structure or can recommend any lawyers or accountants familiar with his structure.