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Asset protection and succession planning management for UPEs and loans paper


This paper covers:

  • overview of estate succession planning strategies
  • overview of asset protection planning strategies
  • overview relationship breakdown planning strategies
  • overview of Div. 7A deemed dividends
  • 2016 & 2018 Federal Budget Div. 7A Amendments
  • overview of Sec. 245 Commercial Debt Forgiveness
  • overview of Sec. 100A Reimbursement Agreements
  • overview of capital gain tax (CGT)
  • creation and discharge and satisfaction of UPE
  • asset revaluation reserve distributions
  • financier or intra-group refinancing or redrawing UPEs
  • bi-partite and tri-partite setting off of UPEs.

Author profile

Ronald Jorgensen CTA
Ron Jorgensen, CTA, 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 Tax Lawyer for 2015, 2016, 2017 and 2018 and as a Leading Tax Lawyer for 2020 and in Best Lawyers Australia 2021. - Current at 16 December 2020
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This was presented at 51st Western Australia State Convention .

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