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Individual Podcasts

Subdivisions EA and EB: Why They Matter More Than Ever After Bendel

The Full Federal Court’s decision in Bendel has cast doubt on the ATO’s view that a UPE to a corporate beneficiary is a loan under Division 7A. But even if the High Court upholds that decision, advisers shouldn’t breathe easy – Subdivisions EA and EB still pose significant risks.

Date/Time

About the Podcast

The Full Federal Court’s decision in Bendel has cast doubt on the ATO’s view that a UPE to a corporate beneficiary is a loan under Division 7A. But even if the High Court upholds that decision, advisers shouldn’t breathe easy – Subdivisions EA and EB still pose significant risks. These provisions can trigger deemed dividends where trust distributions to companies are followed by loans or payments to shareholders or their associates. This episode explores how EA and EB work, the scenarios where they bite, and why section 100A may be the ATO’s next weapon of choice.

Presented By

Danielle Constantine
Partner, William Buck Sydney, NSW

Danielle started her tax career in corporate tax for the financial services and property sector. Since joining William Buck 6 years ago, Danielle has focused on SMEs and has developed experience in a range of industries, including media, retail and property.

Danielle delivers advice on a range of tax issues such as capital gains tax, advice relating to structuring acquisitions and restructuring businesses, small business CGT concessions, tax consolidation, and international tax issues. Danielle also has experience managing audits and reviews with the ATO and revenue offices.

Working closely with the audit team, Danielle frequently reviews tax-effect accounting calculations. Danielle’s calm and reliable approach allows her to work well in high pressured environments, using perspective to make the best decisions.

Communicating technical knowledge to clients is another key skill, as Danielle regularly presents tax updates and training to both internal and external stakeholders, including the Tax Institute. Danielle enjoys working together with her clients and colleagues to practically achieve the best outcome possible.

CPD Information

27 minutes 

0.45 CPD hours/units/points

WA Lawyers – TEN is unable to verify that you have earned CPD for this product as we cannot verify that you have listened to the podcast which is a requirement of the LPBWA.  TEN is an accredited provider.

Enquiries/Assistance

If you need assistance or have an enquiry, please do not hesitate to contact us, on (03) 8601 7700 or email: [email protected]

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