On 2 June 2010, the Tax Office released Taxation Ruling TR 2010/3, the finalised version of the controversial draft TR 2009/D8 on the tax treatment of unpaid present entitlements (UPE) for corporate beneficiaries. The ruling raises exceptionally complex trust and tax law issues which will have hard practical consequences for trustees, beneficiaries and their advisers, some of which need to be considered before 30 June 2010. Although the final ruling is "better' for taxpayers in some respects dangers still abound for taxpayers and their advisors who utilise corporate beneficiaries. The ruling has both retrospective and prospective application depending on what technical issues are seen to be involved.
This seminar provided guidance to tax practitioners on what this new approach means in practice.
The corresponding paper was written by Greg Travers and delivered in Sydney on 23 June 2010, his paper can be downloaded there.
Ian Snook's presentation was also delivered in Darwin on the 6th August 2010 at UPE & Superannuation coming to Darwin.