10/10/2023
The decision in Bendel1 could have significant implications to Division 7A application, challenging the Commissioner’s long-standing position to treat unpaid present entitlements (UPEs) as loans. The Commissioner’s view is that where a company beneficiary of a trust has an UPE, this entitlement will generally be treated as a loan for Division 7A purposes, if it […]
10/02/2023
On 24 January 2023, the Full Court of the Federal Court of Australia handed down its appeal decision in Commissioner of Taxation v Guardian AIT Pty Ltd ATF Australian Investment Trust [2023] FCAFC 3. The Court upheld the original judgement in favour of the taxpayer in relation to the application of section 100A but allowed the […]
24/02/2022
On 23 February 2022 the Commissioner released three draft administrative pronouncements and one Taxpayer Alert which could significantly impact on trust distributions and how they are taxed. The contents of these pronouncements are both voluminous and complex and are still being digested, but essentially relate to the Commissioner’s views on the operation of two integrity […]
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