Unpaid present entitlement paper
Publication date: 11 Jun 09
Source: VICTORIAN DIVISION, THE TAX INSTITUTE
Abstract:
This paper discusses the classification and taxation of loans and unpaid present entitlements under
Division 7A ITAA 1936 and the comments made by Deputy Commissioner Mark Konza on 31 March 2009. Particular topics covered are:
- what constitutes a loan and an UPE
- identification of uncertainties for applying Subdivision EA
- the potential risks of misdescribing a UPE as a loan in the accounts
- the potential application of Division 7A to amount held on sub trust
- the management of sub trust amounts retained by the head trust.
The paper also considers the recent statements in the press regarding the ATO's view on the taxation of trusts.
Author profile:
Ron is a Principal of Harwood Andrews Lawyers and primarily consults on federal and state revenue laws and revenue litigation. Ron also advises in respect of business structuring, tax sensitive commercial transactions and property developments. He is a member of numerous technical and advisory taxation committees with the Taxation Institute and the Law Institute of Victoria. Ron holds a Master of Laws (Taxation) and is a LIV Accredited Specialist in Tax Law.
Current at 01 March 2012
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Unpaid present entitlement
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