This video is a filmed session from the 31st National Convention, PowerPoint slides are incorporated with the presentation.
Often the most accessible source of funding for a private group business or investment activity is the group itself. However, moving funds among private groups has potential adverse taxation implications. This session considered the various tax laws that may apply to transferring funds within commonly controlled private groups, including:
- loans by shareholders and beneficiaries
- debt/equity rules
- taxation of financial arrangements (TOFA) regime
- interest deductibility, including in respect of unpaid present entitlements through chains of entities
- technical analysis of existing legislation with case studies, including effects on UPEs and Div 7A.
Purchase individual materials from this session:
The private funding conundrum
Author(s): Darren Catherall, Greg NIELSEN, William O’Sullivan
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