Over the last couple of weeks, we have seen a significant increase in the level of enquiry about the appropriate strategies to adopt for clients that have trusts with unpaid present entitlements (UPE) owing to corporate beneficiaries.
For some months leading advisers have recommended that any specific steps be delayed for as long as possible on the basis (and hope) that there might be some relaxation or unwinding of the position adopted by the Tax Office. Indeed, there have also been rumours of a test case being run.
Given that it now appears increasingly likely that there will be nothing of substance changing the current rules before 30 June 2011, advisers and clients in this area now have less than eight weeks to have adopted one of the 'safe harbours' provided by the Tax Office.
Until next week.
