Episode 69: Beyond Bendel: When is a UPE not a loan?
In this episode of TaxYak, our Senior Tax Trainers Phillip London and George Housakos yak with Arthur Athanasiou, Tax Partner at Thomson Geer. They take a deep dive into the burning issues resulting from the Full Federal Court's 3:0 decision in favour of the taxpayer in FCT v Bendel issued on 19 February 2025, where an Unpaid Present Entitlement (UPE) was found not to be a loan for the purposes of Division 7A Income Tax Assessment Act (ITAA) 1936. For example: Taxpayer strategies for UPEs for ye...
