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

Published on 19 Feb 10 by THE TAX INSTITUTE

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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