by Gavel Law | Feb 26, 2025 | Gavel Law, Private Wealth, Tax Avoidance, Taxation Law, Trusts
The Commissioner of Taxation (Commissioner) has had a long-standing view that an unpaid present entitlement (UPE) by a trust to a corporate beneficiary is a form of “financial accommodation” where the beneficiary can (but does not) demand the entitlement. This meant...
