TD 2017/D1 – proposal to rule that the wider definition of ‘distributions’ (that catches nearly every transaction at ‘undervalue’) can apply to non-beneficiaries too – s272-60 of Sch 2F, ITAA 1936
TD 2017/D1 was released on Thur 8.6.2017 and says that a person who is not a beneficiary of the trust is capable of having a distribution made to them, for the purposes of s 272-60 of Sch 2F to the ITAA 1936. Trusts can be prevented from carrying forward tax losses, in certain circumstances, if it has ‘distributed…