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Division 7A Day

Published on 22 Nov 2016 | Took place at City West Receptions, West Perth, WA

Division 7A has been around for many years, yet some of its less well-understood applications continue to cause difficulties for practitioners. This event explored some of its more complicated aspects and when they might apply.

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Individual sessions

Section 100A

Author(s):  Patrick Ellwood

This paper covers:

  • Division 6 and the operation of section 100A
  • dealing with tax sheltered amounts
  • common situations that may constitute a reimbursement agreement
  • the meaning of an ‘ordinary family or commercial dealing’
  • the ATO’s guidelines and compliance action.
Materials from this session:

Subdivision EA and interposed entities

Author(s):  Patrick Ellwood

This paper covers:

  • unpaid present entitlements – the ATO view
  • Subdivision EA
  • chains of entitlements between
  • tax planning tips to avoid Subdivision EA
  • policy considerations.
Materials from this session:

Division 7A & divorce - Two certainties - Divorce & taxes

Author(s):  Ron JORGENSEN

This paper covers:

  • dealing with company issues
  • dealing with loan issues
  • dealing with trust issues.
Materials from this session:

Division 7A structuring - The contortionist revisited

Author(s):  Ron JORGENSEN

This paper covers:

  • quarantined loans and UPEs
  • repayment approaches
  • restructuring approaches.
Materials from this session:

Division 7A update

Author(s):  Kenneth WEE

This presentation covers:

  • UPEs
  • effectiveness of Div 7A proofing strategies
  • Div 7A reforms.
Materials from this session: