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Unpaid present entitlement or loan – a Division 7A analysis

Published on 01 Aug 09 by "THE TAX SPECIALIST" JOURNAL ARTICLE

The Commissioner may seek to treat a UPE between a trust and a corporate beneficiary as a s 109D loan. While there is some authority in support, there are strong arguments against the Commissioner’s position.

Author profile

Ronald Jorgensen CTA
Ron principally consults on Commonwealth and State tax laws, tax dispute resolution and compliance enforcement. Ron specialises in trusts and trust disputes, succession and asset protection, business and investment structuring and tax sensitive commercial and property transactions. Ron is an Accredited Specialist Tax Law and member of the Tax Law Advisory Committee with the Law Institute of Victoria. He is a member of the Law Institute of Victoria and The Tax Institute. Ron is a member of the Tax Technical Committee (Vic), a member and former chair of the States Taxes Committee (Vic) and former representative of the Victorian State Taxes Consultative Council for The Tax Institute. Ron is a member of the Property Council of Australia Tax Committee (Victorian Division). Ron was recognised by Doyle’s Guide as a Recommended Leading Tax Lawyer for 2015, 2016, 2017 and 2018. - Current at 07 August 2019
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