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  2024 Division 7A

UPEs and Corporate Beneficiaries – Revisiting Division 7A

Published Date: 26 Mar 2024

 

The recent AAT decision involving Bendel and the Commissioner of Taxation has reignited discussions on the creation of UPEs in corporate beneficiaries.

This presentation addresses some of the division 7A planning issues associated with the above practice, including:

  • Revisiting the history of section 109D(3) and subdivision EA
  • Opportunities and pitfalls in creating UPEs in corporate beneficiaries
  • Ongoing risk-management issues and ATO administrative compliance; and
  • Looking beyond the Bendel decision.

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Author(s)

Individual Session

Author(s): Paul Tanti CTA
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