Draft Taxation Ruling TR 2009/D8 – Sense or nonsense?
Publication date: 11 Feb 10
Source: WESTERN AUSTRALIAN DIVISION, THE TAX INSTITUTE
Abstract:
This paper covers:
- the Conventional Operation of Division 7A
- dealing with later dividends
- interposed entities
- discretion to disregard operation of Division 7A
- the life style asset amendments
- the provenance of Subdivision EA
- The operation of Subdivision EA
- loan agreements and Subdivision EA
- what the draft Ruling Says
- timing - date of effect
- accepting the Ruling - going forward
- UPEs of earlier years
- Section 109RB application
- timing
- financial accommodation
- in-substance a loan
- the examples as part of the Ruling
- comment on Examples
- paying the dividend out
- Section 109ZG
- net Income in Subdivision EA
- Section 100A
- what is left for Subdivision EA?
Author profile:
Kenneth Schurgott FTIA
Ken is a Tax and Commercial Law Partner in the Sydney office of Schurgott Noolan Pty Ltd. Ken has extensive experience in all aspects of tax (including state taxes) as well as business structuring, asset protection, succession planning and trust and estate law. He is a member of the Advisory Panel to the Board of Taxation and is presently heavily engaged in consultation in relation to the reform of the taxation of trusts.
Current at 09 May 2012
Click here to expand/collapse more articles by Ken SCHURGOTT.
Ken is a Tax and Commercial Law Partner in the Sydney office of Schurgott Noolan Pty Ltd. Ken has extensive experience in all aspects of tax (including state taxes) as well as business structuring, asset protection, succession planning and trust and estate law. He is a member of the Advisory Panel to the Board of Taxation and is presently heavily engaged in consultation in relation to the reform of the taxation of trusts.
Current at 09 May 2012
Click here to expand/collapse more articles by Ken SCHURGOTT.
Copyright Statement
