Unpaid present entitlement or loan – a Division 7A analysis
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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 State
Revenue Office (Victoria). Ron holds a Master of Laws (Taxation) and is an LIV Accredited Specialist in Tax Law.
Current at 01 August 2010
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