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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:

Ken SCHURGOTT
Ken is a tax and commercial law partner in the Sydney office of SBN Lawyers. He has extensive experience in all aspects of tax (including State taxes) as well as business structuring, asset protection, succession planning and trust and estate law. Ken is a National Councillor of the Tax Institute and a member of the NSW Divisional Council and Education Committee. He is also a member of the Advisory Panel to the Board of Taxation and has recently been involved as a member of the Working Group on Managed Investment Trusts.
Current at 13 January 2009
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