Angel of Death, Section 100A & Other UPE-Related Estate Planning Challenges

Discover the ‘Angel of Death’ strategy, plus how to deal with unpaid beneficiary entitlements during the estate planning process.

In this session, we cover:

• UPEs and sub-trusts 101​

  • What is an Unpaid Present Entitlement (UPE)?​

  • What is a sub-trust?​

• Division 7A & Death​

  • Division 7A refresher​

  • ATO ID 2002/741​

  • Forgiveness​

  • ATO ID 2012/77​

• Section 100A & Death​

  • Section 100A refresher​

  • Section 100A and estate planning​

  • TR 2022/4, example 6​

• Family Trust Elections​

  • What is a Family Trust Election (FTE)?​

  • The family group​

  • Members of the test individual’s family​

  • Interposed Entity Elections (IEE)​

  • Family Trust Distribution Tax (FTDT)​

• Corporate Beneficiary Strategies​

  • The conundrum​

  • Angel of Death​

Download the resources here.

Date recorded: 19 May 2025