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Draft Taxation Ruling TR 2009/D8 – Sense or nonsense?

Published on 11 Feb 10 by WESTERN AUSTRALIAN DIVISION, THE TAX INSTITUTE

This paper covers:

  • the Conventional Operation of Division 7A
  • dealing with later dividends
  • interposed entities
  • discretion to disregard operation of Division 7A
  • the life style asset amendments
  • the provenance of Subdivision EA
  • The operation of Subdivision EA
  • loan agreements and Subdivision EA
  • what the draft Ruling Says
  • timing - date of effect
  • accepting the Ruling - going forward
  • UPEs of earlier years
  • Section 109RB application
  • timing
  • financial accommodation
  • in-substance a loan
  • the examples as part of the Ruling
  • comment on Examples
  • paying the dividend out
  • Section 109ZG
  • net Income in Subdivision EA
  • Section 100A
  • what is left for Subdivision EA?

Author profile:

Author Photo - Kenneth Schurgott CTA-Life
Kenneth Schurgott CTA-Life
Ken is a Tax and Commercial Law Director of Schurgott & Co Lawyers and Special Counsel with Brown Wright Stein Lawyers, Sydney. He has extensive experience in all aspects of tax (including state taxes and litigation), as well as business structuring, business sales and acquisitions, asset protection, succession planning and trust and estate law. Ken has been, until recently, a member of the Advisory Panel to the Board of Taxation and heavily engaged in ongoing consultation in relation to the reform of the taxation of trusts and trust issues generally. Current at 28 July 2016 Click here to expand/collapse more articles by Ken SCHURGOTT.
 
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