Miscellaneous 2010

Unpaid present entitlements

Published Date: 29 Jun 2010

 

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On 2 June 2010, the Tax Office released the final ruling of its 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 pre 30 June 2010. The ruling has both retrospective and prospective application depending on what technical issues are seen to be involved.

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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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