Division 7A loans: trust entitlements - TR 2009/D8
This draft Taxation Ruling was released on 16 December 2009 for public comment by 12 February 2010. Its full title is "Income tax: Division 7A loans: trust entitlements".
The draft Ruling expresses the Commissioner's opinion on the circumstances in which a private company with a present entitlement to an amount from an associated trust estate, in circumstances where funds representing that present entitlement remain intermingled with funds of the trust, may or may not be taken to have made a loan to that trust within the meaning of s 109D(3) of Division 7A of Part III (Division 7A) of ITAA 1936.
It is proposed that the final Ruling will apply both before and after its date of issue where an actual loan is made.
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