Miscellaneous 2010

Draft Taxation Ruling TR 2009/D8 " Sense or nonsense?

Published Date: 11 Feb 2010

 

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This paper covers:

  • the Conventional Operation of Division 7A
  • dealing with later dividends
  • interposed entities
  • discretion to disregard operation of Division 7A
  • the life style asset amendments
  • the provenance of Subdivision EA
  • The operation of Subdivision EA
  • loan agreements and Subdivision EA
  • what the draft Ruling Says
  • timing - date of effect
  • accepting the Ruling - going forward
  • UPEs of earlier years
  • Section 109RB application
  • timing
  • financial accommodation
  • in-substance a loan
  • the examples as part of the Ruling
  • comment on Examples
  • paying the dividend out
  • Section 109ZG
  • net Income in Subdivision EA
  • Section 100A
  • what is left for Subdivision EA?

Details

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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Miscellaneous 2010

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