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Unpaid Present Entitlements - A new approach to taxing trust distributions

Published on 23 Jun 2010 | Took place at Swissotel Sydney, Sydney, NSW

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.

This event identified the issues addressed by the ruling, considered the basis of the Tax Office’s position and provided guidance to tax practitioners on what this new approach means in practice.

Greg Travers paper was also presented in Darwin on the 6th August 2010 at UPE & Superannuation coming to Darwin.

Individual sessions

Final ruling TR2010/3 - Income tax: Division 7A loans: Trust entitlements

Author(s):  Greg TRAVERS This paper covers:

  • ordinary loans
  • loans within the extended meaning
  • sub trusts
  • other issues.
Materials from this session: