Division 7A redefined – Navigating unpaid present entitlements post-Bendel decision
Last week’s unanimous Full Federal Court decision in Commissioner of Taxation v Bendel (“Bendel”) indicates that the Australian Tax Office’s (ATO) views since December 2009 about unpaid present entitlements (“UPEs”) should no longer be sustainable in the context of Division 7A. While we wait for further announcements from the ATO or the Federal Government (regarding […]