Unpaid Present Entitlements - A New Approach to Taxing Trust Distributions
Published on 11 Feb 2010
| Took place at Swissotel Sydney, Sydney, NSW
Just before Christmas, the Tax Office released a very controversial draft ruling on the tax treatment of unpaid
present entitlements (UPE). The draft ruling raises exceptionally complex trust and tax law issues which will have
hard practical consequences for trustees, beneficiaries and their advisers. The draft ruling is intended to have
both retrospective and prospective application depending on what technical issues are seen to be involved.
This event identified the issues addressed by the draft ruling, considered the basis of the Tax Office’s position and provided guidance on practical responses to this new approach.