Sladen Events
Filtering by: “UPEs”
May
6
After Bendel: Division 7A, Anti-Avoidance, and Beyond
The Full Federal Court’s decision in Commissioner of Taxation v Bendel (February 19, 2025) has redefined the tax landscape for trusts, ruling that unpaid present entitlements (UPEs) between a corporate beneficiary and a trust do not constitute a loan under s109D(3) of Division 7A.