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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

Paul Hockridge CTA
Photo of author, Paul HOCKRIDGE Paul of Mutual Trust, has over 30 years experience in advising high-wealth families, closely held businesses and accounting and legal firms on tax, asset protection and estate and succession planning. He has particular expertise in litigation support and property development. Paul started his career with the ATO and has worked in major legal and accounting firms. Prior to joining Mutual Trust, he was a Tax Partner at Deloitte Private for several years. For a number of years, Paul has been a regular author and speaker on taxation matters, particularly in relation to tax aspects of business and investment structuring, estate and succession planning and salary packaging. - Current at 26 September 2017
Click here to expand/collapse more articles by Paul HOCKRIDGE.

 

This was presented at 51st Victorian State Convention .

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