A home for tax nerds.
Hi, I’m Ken. Being a stay at home Dad to two amazing boys and one awesome wife is wonderful, but it does keep me away from my fourth love – TAX. So here I write on what is happening in tax that excites me, and hopefully it will excite you as well…
No Div 7A on UPEs (unpaid present entitlements) to corporate beneficiaries… the Federal Court says stop to the Commissioner!! Wow
The Federal Court just said Division 7A does NOT apply to an unpaid present entitlement to a corporate beneficiary unless there is a loan to an individual shareholder as well!!!! See Commissioner of Taxation v Bendel [2025] FCAFC 15 (19 February 2025). They write…. “Division 7A is an anti-avoidance provision directed at in substance distributions…
POLICY IDEA – FIXING PRIVATE COMPANY DEEMED DIVIDENDS… WITH DEEMED INTEREST
Sorry but I had to much thinking time over the Christmas holidays… Many tax agents have a story of a new client where, sitting on the balance sheet of a private company in the group, there are loan accounts to shareholders or their associates. While this in itself is not a problem, the tax agent…
Indexing rates in the tax legislation
When the idea of indexing rates and thresholds in the tax legislation is discussed, it is often discussed in terms of bracket creep that occurs due to the individual income tax thresholds not being indexed. However, while this is a great example of this issue (if the highest threshold had have been indexed for CPI…
Paris Tax Olympics
The second biggest party in French parliament after recent election has a new proposal… The want a new 90% tax on any annual income above €400,000 Currently the highest tax rate is 45% on income over €177,106 Kylian Mbappé (a football player for those who don’t know) received a monthly salary of €𝟔m at Paris Saint-Germain –…
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