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  2003

Division 7A: Dante's Inferno

Source: New South Wales

Published Date: 19 Feb 2003

 
So your client has a shareholder loan: Do you feel hot?

In Dante's world, the earth is at the centre of the universe and Hell is a vast funnel-shaped cavity. The sides of the cavity form a succession of concentric levels in diminishing circles as they approach the centre. The deeper you go the more serious the sin. Which brings us to Division 7A.

Step into the shoes of Dante and pass through the gates of the Tax Act towards the inferno that is Division 7A.

Some of the many difficult issues covered included:
- Section 109UB and trusts and the Treasurer's announcement
- What is a beneficiary account?
- Traps when liquidating a company
- Rulings and determinations that have turned 'up' or 'down' the heat
- Cases of sinners and the reaction of the courts
- Profits and the ATO's attitude to internally generated goodwill
- The anti-avoidance rules within Div 7A
- Section 108 and its relevance
- Prepaying interest on Div 7A loan.

Purgatory and paradise - a quick overview of Division 7A

Author(s): Zoe Myers
Materials from this session:

Descending into the inferno

Author(s): Joe Lombardo
Materials from this session:

Ascending from the inferno

Author(s): Kevin O'Shaughnessey
Materials from this session:

Details

  • Published On:19 Feb 2003
  • Took place at:The Menzies Hotel, Sydney

The material is copyright. Apart any fair dealing for the purpose of private study,

research critisism or review, as permitted under the copyright Act, no part may be rerpoduced by any process without written permission from The Tax Institute.

Unless expressly stated, opinions are not that of The Tax Institute, which accepts no responsibility for the accuracy of any of the information contained within it.

This material is copyright. Apart from any fair dealing for the purpose of private study., research, critisism or review, as permitted under teh copyright Act, no part may be reproduced by any process without written permission from The Tax Institute.

Unless expressly stated, opininons are not that of The Tax Institute, which accepts no responsibility for the accuracy of any of the information contained within it.

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