Published on 29 Jun 10
On 2 June 2010, the Tax Office released the final ruling of its controversial draft TR 2009/D8 on the tax treatment of unpaid present entitlements (UPE) for corporate beneficiaries. The ruling raises exceptionally complex trust and tax law issues which will have hard practical consequences for trustees, beneficiaries and their advisers, some of which need to be considered pre 30 June 2010. The ruling has both retrospective and prospective application depending on what technical issues are seen to be involved.
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