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. Thus, the Commissioner’s heterodox view [...]
"We have published an article titled 'Structural Choices for Expanding into the US: An Issue-Driven Analysis' in The Tax Specialist. The article explores the US, Australian, and treaty issues that arise from concurrent business operations in both countries. It is awe-inspiring to sail down the confluence of the wild rivers of US [...]
While it is a great outcome to keep as much of your money in your super as is possible, you do need to be conscious that at some point, the remaining balance may be passed onto the next generation, potentially as a part of their inheritance, with a tax liability. When this money does [...]