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Draft taxation ruling TR 2009/D8 - Sense or nonsense presentation?

Published on 11 Feb 10 by NEW SOUTH WALES DIVISION, THE TAX INSTITUTE

This presentation covers:

  • what is a UPE?
  • what the draft ruling says
  • potted history of Division 7A
  • Subdivision EA
  • Division 7A general issues
  • Section 109D(3) loan
  • Section 109C (3) payment
  • accepting the ruling - going forward
  • UPEs of earlier years
  • financial accommodation
  • in-substance a loan
  • the perpetual motion machine.

Author profile

Kenneth Schurgott CTA-Life
Ken is a Solicitor - Director of Schurgott & Co Lawyers specialising in taxation matters (including State Taxes, stamp duty, payroll tax and land tax) and with extensive experience in business structuring, business sales and acquisitions, asset protection, succession planning and trust and estate law. Ken is very experienced in tax dispute matters, negotiations for settlements, mediations and conciliations and litigation. He regularly appears before the AAT and NCAT and instructs counsel in matters before the Courts. Ken was National President of the Institute in 2012. - Current at 01 October 2019
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