Published on 09 Sep 04
by VICTORIAN DIVISION, THE TAX INSTITUTE
This paper focusses on the Div 7A loan debt/equity interaction in SME structures used to maximise capital retention, asset protection and deductions. The issues
- corporate beneficiaries and loan backs
- trust loans to shareholders
- on lending in an SME group
- on lending and consolidation
- impact on total holdings
- exploitabilities - there are some!
- limiting your practice risk.
Chris commenced practice as a Barrister in 1991 and 27 years later has a strong no nonsense reputation throughout Australia in the fields of equity and revenue law. Chris’ focus is on keeping clients out of the AAT and Court using attention to detail and negotiation to secure certainty for clients at the earliest opportunity, a focus which has involved him in numerous in-house facilitation sessions. Chris is a regularly published author and a member of the Editorial Board of the Australian Tax Law Bulletin and also of the Australasian Tax Teachers Association (ATTA). Chris presents regularly throughout Australia for the professional bodies and ATTA and has completed studies in international tax at the Institute for Austrian and International Tax Law at Wirtschafts Universitat in Vienna and the IBFD in Amsterdam. Two of Chris' recently published articles have addressed issues arising under the ATO's in-house facilitation process. Subsequent changes to the process reflected observations in the articles.
- Current at
08 October 2019