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Self-funding a private group business or investment, including Div 7A and trust considerations video
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Member Price: $99.00
Non Member Price: $121.00
Publication date: 02 Mar 16 | Source: NATIONAL DIVISION, THE TAX INSTITUTE
Abstract:
This video is a filmed session from the 31st National Convention, PowerPoint slides are incorporated with the presentation.
Often the most accessible source of funding for a private group business or investment activity is the group itself. However, moving funds among private groups has potential adverse taxation implications. This session considered the various tax laws that may apply to transferring funds within commonly controlled private groups, including:
- loans by shareholders and beneficiaries
- debt/equity rules
- taxation of financial arrangements (TOFA) regime
- interest deductibility, including in respect of unpaid present entitlements through chains of entities
- technical analysis of existing legislation with case studies, including effects on UPEs and Div 7A.
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The private funding conundrum
Author(s):
Darren Catherall,
Greg NIELSEN,
William O’Sullivan
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Author profile
Gregory Nielsen CTA
Greg is a partner/executive director in the Tax Consulting division of Pitcher Partners Melbourne. He specialises in providing taxation advice to the SME corporate sector on a wide range of taxation issues. Greg joined Pitcher Partners in 1999 and was admitted to the partnership in 2008. He is a representative for CPA Australia and the SME market as a participatory member of the ATO Private Group Stakeholders Group. Greg is also a qualified legal practitioner and has practiced as a tax lawyer in a number of mid-tier law firms in Melbourne. - Current at 01 June 2020
This was presented at 31st National Convention .
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