We’ve had a win… a UPE is not a loan!
3 Oct 2023
After 11 months of eagerly waiting, our client, Mr. Bendel, has won in Bendel v Commissioner of Taxation. The AAT has ruled that an unpaid present entitlement (“UPE”) of a corporate beneficiary against a trust is not a loan within the meaning of s109D(3) of ITAA 36…..
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