Getting Tax Structuring Right - Trusts, Companies and Division 7A – taxation Power Pair of recorded webinars

This Power Pair comprises 2 of our most popular taxation webinars from the past year.
 

Webinar 1: Looped Loans and Division 7A: When Repayments Trigger Tax Trouble

Repaying a loan in part or in full from a private company in the required timeframe, or entering into a complying loan arrangement with an obligation to make minimum yearly loan repayments, are ways to minimise the adverse tax consequences that Division 7A can bring. So, can you use funds from the same company the loan is with to repay the loan in part or in full, or to meet the minimum yearly repayments? This session explores the legislation and the ATO’s views on the matter, including:

• How the ATO views a loan from a private company to repay a loan from that same company
• How the “reasonable person test” is applied
• How the tracing rules can apply for loan repayment arrangements which involve interposed entities (TD 2025/D2)
• Issues arising in practice due to the recent spike in the statutory interest rate
• Strategies to consider involving refinancing (secs. 109R(5), (6) & (7))
• Is there any Commissioner discretion available to allow repayments that may otherwise be disregarded?
• Practical examples

Webinar 2: From Trust to a Company: Making the Switch Without the Tax Sting

The use of trusts can bring about numerous benefits. However, they are becoming increasingly complex to administer and they can pass their use by date, not just with a reference to their “vesting date”, but also with a reference to the benefits of using an alternative corporate structure that for some situations may provide more pros than cons. This session looks into when it may be time to consider a change, and if so, how to tax effectively manage the process, including:

• The pros and cons of the use of a trust structure versus the use of a company structure
• The situations that may be conducive to changing from a trust structure to a company
• The various methods that can be used to tax effectively change a trust structure to a company and the pros and cons of each 
• Can restructure/rollover options be a viable option when a trust is approaching or past its vesting date?
• Are there any methods to change a trust structure to a company that can: 
  • keep the history for the potential future use of the small business CGT 15 year exemption intact?
  • remove “skeletons in the closet” from the trust's trading history for asset protection purposes?
• How the asset mix of a trust entity impacts on the decision of choosing the option to use for a change
• The issues besides income tax and capital gains tax that a tax practitioner should be mindful of when advising on the alternative approaches
• Case study

Special Purchase Offer - The April Advantage

This pair of recorded webinars would usually cost $539, but as part of The April Advantage Offer you can buy the pair for only $330 if you order by 30.4.26.