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Unpaid present entitlements - Division 7A – UPEs – The red wine experiment paper

Published on 02 Mar 11 by NATIONAL DIVISION, THE TAX INSTITUTE

This paper covers:

  • foundations of Division 7A
  • review of Commissioner's technical analysis
  • impact on past and future corporate beneficiary distributions
  • impact on trust deed, resolutions & accounts
  • preparing complying sub trusts & loans
  • corrective action
  • choice of entity & restructuring.

Author profile

Ronald Jorgensen CTA
Ron principally consults on Commonwealth and State tax laws, tax dispute resolution and compliance enforcement. Ron specialises in trusts and trust disputes, succession and asset protection, business and investment structuring and tax sensitive commercial and property transactions. Ron is an Accredited Specialist Tax Law and member of the Tax Law Advisory Committee with the Law Institute of Victoria. He is a member of the Law Institute of Victoria and The Tax Institute. Ron is a member of the Tax Technical Committee (Vic), a member and former chair of the States Taxes Committee (Vic) and former representative of the Victorian State Taxes Consultative Council for The Tax Institute. Ron is a member of the Property Council of Australia Tax Committee (Victorian Division). Ron was recognised by Doyle’s Guide as a Recommended Leading Tax Lawyer for 2015, 2016, 2017 and 2018. - Current at 07 August 2019
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This was presented at 26th National Convention .

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Speed updating

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