This comprehensive course illustrates the application of all the substantive provisions of Division 7A set out in Subdivisions A to F. The complex issues relating to Division 7A of the Income Tax Assessment Act (1936) (the ITAA) are explained via case studies, and include invaluable tips, tax traps and warnings throughout.
This course consists of one hard copy learning manual and one online assessment.
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Understand how Division 7A applies to payments, loans and debt forgiveness by private companies to shareholders, former shareholders, other equity-holders and certain associates
Identify when cash payments, credited amounts, transfers of property and the provision for the use of assets are deemed payments by private companies to entities, including all related exemptions, planning strategies and the operation of the interposed entity anti-avoidance provisions
Determine when advances, the provision of credit or the making of an in substance debt will be deemed to be loans made by private companies to associated entities
Review scenarios where a debt forgiveness can arise, and the exclusions and strategies that may apply to mitigate any tax exposure
Recognise that the amount of any deemed dividend is limited by the private company’s distributable surplus, and the scope of the Commissioner’s discretion to disregard the application of Division 7A
Examine when unpaid present entitlements owed by trusts to private company beneficiaries are deemed loans, and the concessions potentially available to mitigate that liability
Highlight the extension of Division 7A to trusts where the trust enters into a payment, loan or debt forgiveness transaction with a shareholder or associate of a private company
Illustrate the interaction of Division 7A and other key tax provisions
Tax professionals working in Public Practice or corporate and SME entities with responsibilities requiring detailed knowledge of the provisions of Division 7A.
This course is based on the Australian taxation system.