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Division 7A: Hotspots with common structures and strategies paper

Published on 11 Oct 12 by VICTORIAN DIVISION, THE TAX INSTITUTE

With the ATO blowtorch squarely aimed at Div 7A, this paper turns the heat up on Div 7A issues arising from common structures and strategies post
16 December 2009, together with possible ways of dealing with them.

Issues to be examined include:

  • multi-layered entities, creating multiple Div 7A problems 
  • loans and payments through interposed entities
  • strategies to deal with UPEs, including transferring receivables
  • UPEs becoming loans because of the trust deed
  • non-resident companies and/or shareholders
  • the use of property – when and how to value it?
  • the use of guarantees, security and subrogating rights to UPEs.

Author profile:

Author Photo - Paul Hockridge CTA
Paul Hockridge CTA
Paul is a Tax Partner at Mutual Trust with over 30 years' experience in tax, asset protection, estate succession planning, FBT and salary packaging. Paul specialises in advising high wealth families and closely held businesses as well as many accounting and law firms. Paul teaches in the Masters program in the Law School at the University of Melbourne and has been involved in consultation with both federal and state governments on a variety of tax matters. Current at 08 July 2015 Click here to expand/collapse more articles by Paul HOCKRIDGE.
 

This was presented at 51st Victorian State Convention.

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