Draft taxation ruling TR 2009/D8 - Sense or nonsense paper?
Publication date: 11 Feb 10
Source: NEW SOUTH WALES DIVISION, THE TAX INSTITUTE
Abstract:
This paper covers:
- general operation of Division 7A
- the historical understanding of the operation of Subdivision EA of Division 7A
- the technical basis of the ATO's new approach
- the retrospective and prospective application
- the financial consequences of the draft ruling applying
- the virtual elimination of Subdivision EA
- what practical approaches should be adopted in response
- is a legislative fix needed?
Author profile:
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
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Draft taxation ruling TR 2009/D8 - Sense or nonsense?
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