A significant decision was handed down in the Federal Court which impacts the Division 7A consequences of unpaid trust distributions to corporate beneficiaries. The Court ruled against the ATO in Commissioner of Taxation v Bendel [2025] FCAFC 15 which essentially goes against a ruling the ATO issued in 2010 dealing with the application of Division 7A on unpaid present entitlements (UPEs) owed to corporate beneficiaries.