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.
Paul Hockridge FTIA is a Tax Partner at Deloitte with over 30 years
experience in Tax, asset protection, estates-succession planning,
FBT and salary packaging. Paul specialises in advising high wealth
families and closely held businesses and advises mainly accounting
and law firms. Paul is a member of various professional association
committees and has been involved in consultation with both Federal
and State Governments on a variety of tax matters. Current at 17 October 2008
The Tax Institute is a Recognised Tax Agent Association (RTAA) under the Tax Agent Services Regulations 2009.
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