Published on 11 Oct 12
by VICTORIAN DIVISION, THE TAX INSTITUTE
With the ATO blowtorch squarely aimed at Div 7A, this presentation 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.