subtrusts

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TD 2022/11: ATO finalises views, relief for some taxpayers but a sting for others

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TD 2022/11: ATO finalises views, relief for some taxpayers but a sting for others

We wrote about Draft Taxation Determination TD 2022/D1 (Draft TD) on Division 7A and unpaid present entitlements (UPEs) here. On 12 July 2022, the Australian Taxation Office (ATO) finalised the Draft TD as Taxation Determination TD 2022/11 (Final TD).

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PCG 2017/13: sub-trust arrangements – welcome (continued) relief from the ATO

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PCG 2017/13: sub-trust arrangements – welcome (continued) relief from the ATO

Draft Taxation Determination TD 2022/D1 sets out the Australian Taxation Office’s (ATO) views on when an unpaid present entitlement (UPE) with a corporate beneficiary is a loan for the purposes of Division 7A of the Income Tax Assessment Act 1936. We wrote about TD 2022/D1 here.