Posts

406 | UPE To Company: The Bendel Case

From 2009 until October 2023, a UPE to a company was always a Div 7A issue. Not anymore. As Andrew Henshaw of Velocity Legal in Melbourne will tell you.

s100A pain points

Update 35 | s100A Pain Points

There are many s100A pain points - let's cover five in this update.

Update 34 | s100A B Blood and Guardian case

The two s100A B Blood and Guardian cases cover some very specific scenarios. And not common examples.

Update 33 | Updated s100A TR and PCG

Updated s100A TR and PCG - get the updated review of ATO's approach to s100 issues. Avoid reimbursement arrangements.

Div 7A Loan Write - Off

354 | Div 7A Loan Write – Off

Will a Div 7A Loan write-off trigger a deemed dividend under s109F ITAA36? That is the question.

Distributable Surplus

353 | Distributable Surplus

Distributable surplus is one of five Div 7A quick fixes. If you have no distributable surplus, no deemed Div 7A dividend.

lrba

339 | TD 2022 / D1

The issue of UPEs to companies is nothing new. It is an old problem. But TD 2022/D1 reflects a new ATO approach to this old problem. 

332 | Div 7A Past Amendment Periods

Div 7A past amendment periods might allow you to get out of jail tax-free.

261 | How To Avoid s109T

s109T is an issue when the recipient of a Div 7A loan isn't a shareholder but minimum yearly repayments are financed via a dividend.

Div 7A Dividends

260 | Div 7A Dividends

To offset a dividend with Div 7A loan repayments, the key issue is timing as Robyn Jacobson of The Tax Institute will tell you in this episode.

shareholder loan write off

153 | Shareholder Loan Write Off

What happens if a shareholder gives a loan to a company and then writes it off?  Andrew Henshaw of Velocity Legal will give you an answer.

152 | DIV 7A Reform

What will the upcoming Div 7A reform look like? Andrew Henshaw of Velocity Legal in Sydney gives a good overview.

151 | Div 7A Listener Questions

In this episode Andrew Henshaw of Velocity Legal in Sydney will answer three Div 7A listener questions.

Div 7A UPE

150 | Div 7A UPE Issue

When does a UPE become a Div 7A UPE issue? Andrew Henshaw of Velocity Legal in Sydney will give you an answer.

Div 7A fixes

149 | Div 7A Fixes

Here are 10 easy ways to fix Div 7A issues. This is an edited extract of Tax Talks episode 50 with Peter Adams.

Div 7A Concept

148 | Div 7A Concept

Div 7A tries to stop cash leaking from private companies to shareholders and associates outside of dividend payments. Here is Peter Adams of Augmentors for the details.

Div 7A debt forgiveness

52 | Div 7A Debt Forgiveness

Div 7A debt forgiveness is less common than Div 7A loans and payments, but still important to get right. Peter Adams of Augmentors will discuss the details with you. 

Div 7a Payments

51 | Div 7A Payments

Div 7A payments can turn into an expensive exercise. Including transfer or provision of company assets. Peter Adams of Augmentor will tell you what this is all about. 

Div 7A loans

50 | Div 7A Loans

Div 7A loans are tricky but there are ways out.  As Peter Adams of Augmentors in Sydney will tell you.

Articles

Div 7A UPE

70 | Div 7A UPE

The scenario of a Div 7A UPE can result in a huge tax bill.  UPE stands for unpaid present entitlement.
Structuring Business and Wealth

61 | Structuring Business and Wealth

When structuring business and wealth, tax is just one part of the equation. It is a balancing act of many objectives. And a question of priorities.