Bendel v FCT: ATO’s Treatment of Unpaid Present Entitlements now in Question
Back on 16 December 2009 the Australian Taxation Office (ATO) released its draft Taxation Ruling TR 2009/D8 (later finalised as TR 2010/3) which provided that an unpaid present entitlement (UPE) of a corporate beneficiary was a loan from the corporate beneficiary to the relevant trust for purposes of Division 7A