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  Income tax

Draft Taxation Ruling TR 2009/D8 Income Tax: Division 7A loans: trust entitlements

Author: Taxation Institute Of Australia,Icaa,National Institute Of Accountants,Taxpayers Australia Inc,Cpa Australia

Published Date: 19 Feb 2010

 

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Our submission sets out our concerns on the following key issues:

1. the divergence of the views expressed in the draft Ruling with the underlying policy intent of Division 7A

2. the application of section two of the draft Ruling concerning the extinguishment of a unpaid present entitlement (UPE) and its conversion into a loan

3. the application of section three which provides that a subsisting UPE may amount to either the provision of financial accommodation or an in-substance loan under section 109D(3)

4. the residual application of Subdivision EA; and

5. certain adverse tax consequences which arise from the draft Ruling.

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  • Published By:Taxation Institute Of Australia,Icaa,National Institute Of Accountants,Taxpayers Australia Inc,Cpa Australia
  • Published On:19 Feb 2010
  • Session Name:Draft Taxation Ruling TR 2009/D8 Income Tax: Division 7A loans: trust entitlements
  • Read Time:10+ minutes

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