Unpaid present entitlement or loan – a Division 7A analysis
Publication date: 01 Aug 09
Source: "THE TAX SPECIALIST" JOURNAL ARTICLE
Abstract:
The Commissioner may seek to treat a UPE between a trust and a corporate beneficiary as a s 109D loan. While there is some authority in support, there are strong arguments against the Commissioner’s position.
Author profile:
Ronald Jorgensen FTIA
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 June 2011
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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 June 2011
Click here to expand/collapse more articles by Ron JORGENSEN.
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