Category Archives: Div 7A

Division 7A comes under scrutiny

 Since its introduction into the Income Tax Assessment Act 1936 in 1998 , Div 7A has been sanctioned, censured and reviled by shareholders, trustees and beneficiaries alike. The impact of Div 7A  on companies and trusts used in business structuring has been the main cause of such reaction. During the past decade and more, several issues surrounding Div 7A have female viagra risen requiring a concerted effort  by the government. Now the Board of Taxation has been commissioned to undertake  a post-implementation … Continue reading

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Unpaid present entitlement – pre 16 December 2009

The lethal mix of trusts and Div 7A never stop to boggle the mind. Add taxation rulings and determinations and that’s an alchemist’s dream of a trip, a trap and an ambush. That’s what happened with the release of the mega ruling TR 2010/3 last year. The nightmare continues with the recent release of two new Determinations: TD 2011/15 and TD 2011/16. The views of the tax office about the circumstances in which an unpaid present entitlement (UPE) of a … Continue reading

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