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Unpaid present entitlement or loan – a Division 7A analysis

The Tax Specialist | 1 Aug 09
 
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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 Property and Commercial Law Committee of the Law Society of Tasmania. Ron is a Chartered Tax Advisor and member and former chair of the States Taxes Committee (Vic) of The Tax Institute. Ron was recognised by Doyle’s Guide Leading Tax Lawyer - Victoria for 2015 to 2021 and Best Lawyers for tax law - Australia 2021 and Global 2021. - Current at 16 July 2021
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