Division 7A and UPEs – The Road Ahead

The tax and regulatory environment for small and medium sized
businesses continues to evolve at a rapid pace with
Treasury releasing a consultation paper proposing changes to  Div  7A in October 2018.    
Scheduled to  commence on 1 July
2019, we spoke with Chris 
about the proposed Div 7A
In recent times, Chris has participated in confidential consultation
sessions with representatives from Treasury, the Board of Taxation and the
ATO about the upcoming changes to 
Div  7A as well as being a member of
the Board of Taxation’s reference group for its review of small business tax
When asked what he believed the blind spots where in this area,
explained that ‘at a technical
level, they include the interposed entity rules (s109T) as well as
those involving trusts with UPEs owed directly or indirectly to corporate
At a practical level,  he
believed ‘the biggest blind spot would have to be the cash flow crunch in
a couple of years’ time if the changes go through as currently
Now running his own specialist tax consulting practice, for nearly four
years up to February 2019, Chris was a principal in the tax consulting division
of Deloitte Private, specialising in tax issues confronting privately owned
businesses and family groups.
Chris  will be
presenting on ‘Division 7A and UPEs – The Road Ahead’
at the  SME
/ Private Clients Day One
Melbourne on 28 March 2019.
His session will cover the  codification
of the 
Div  7A
treatment of unpaid trust distributions, about which he has been in discussions
with Treasury. The session also covers the changes to 
Div  7A described in Treasury’s
consultation paper released 
last year.  
Chris anticipates
the session will ‘provide delegates with
sound understanding of how the proposed changes will affect their clients and
some strategies to mitigate those effects’.
When asked what delegates can take away from his session, Chris explained,
will take away an increased awareness
of the likely practical effects of the proposed changes as well as some tools
or techniques to minimise the pain’.
When asked about his interest outside of tax, Chris  confided his love for woodworking and cycling. He
also admitted, “In the past, my wife and I have competed with
friends in interstate and international hot air ballooning championships
(and even won one!)”.
However, when it comes to Division 7A, this is one practitioner that is
not full of hot air.
Find out more about Chris’ session, and the rest of the program on
our website


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