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Fear and loathing in Division 7A: A savage journey to the heart of the UPE dream paper

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Published on 28 Oct 10 by SOUTH AUSTRALIAN DIVISION, THE TAX INSTITUTE

This paper covers case studies with a focus on:

  • what a "Section 2 loan" is and how you avoid one
  • what a "Section 3 loan" is and do you avoid one
  • when a sub-trust will arise
  • what the required return on a UPE is so that it will not be a loan
  • when a section 3 loan arises.

Author profile

Paul Sokolowski CTA
Photo of author, Paul SOKOLOWSKI Paul Sokolowski, CTA, is a partner at Arnold Bloch Leibler, and is the national leader of the firm’s taxation practice. Paul advises clients, including high-networth individuals, large private groups and public entities in tax reviews, audits, disputes and litigation, and in domestic and international transactions. Paul is a regular speaker and writer for the Tax Institute, and other organisations and publications. He actively contributes to tax policy, legislative, technical and administrative development and debate. In March 2019, Paul won The Tax Institute’s 2019 Chartered Tax Advisor of the Year Award. - Current at 06 December 2024
Click here to expand/collapse more articles by Paul SOKOLOWSKI.

 

This was presented at 2010 South Australian Tax Intensive .

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Fear and loathing in Division 7A: A Savage journey to the heart of the UPE dream

Author(s):  Paul SOKOLOWSKI

Materials from this session:

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