In this episode of TaxVibe, host Robyn Jacobson and tax expert John Storey delve into the complexities of Australian tax law. They explore the inherent challenges of tax legislation, discussing the differences between principles-based and black-letter drafting, the evolution of tax laws, and the impact of government actions on tax complexity. The conversation highlights the unavoidable and avoidable complexities within the tax system, the consequences of retrospective legislation, and the rol...
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In this episode of TaxVibe, host Robyn Jacobson and tax expert John Storey delve into the complexities of Australian tax law. They explore the inherent challenges of tax legislation, discussing the differences between principles-based and black-letter drafting, the evolution of tax laws, and the impact of government actions on tax complexity. The conversation highlights the unavoidable and avoidable complexities within the tax system, the consequences of retrospective legislation, and the rol...
For the past 16 years, the question of whether an unpaid present entitlement (UPE) is a loan for Division 7A purposes has challenged the tax profession. Now, in a landmark ruling, the Full Federal Court has delivered its judgment in Commissioner of Taxation v Bendel [2025] FCAFC 15 (Bendel) – confirming that a corporate beneficiary’s UPE is not a loan for Division 7A purposes. This finding has significant implications for taxpayers, tax practitioners and the ATO. Following the decision, this ...
TaxVibe
In this episode of TaxVibe, host Robyn Jacobson and tax expert John Storey delve into the complexities of Australian tax law. They explore the inherent challenges of tax legislation, discussing the differences between principles-based and black-letter drafting, the evolution of tax laws, and the impact of government actions on tax complexity. The conversation highlights the unavoidable and avoidable complexities within the tax system, the consequences of retrospective legislation, and the rol...
