The Resource A question of attribution problems with the hedging election under TOFA

A question of attribution problems with the hedging election under TOFA

Label
A question of attribution problems with the hedging election under TOFA
Title
A question of attribution problems with the hedging election under TOFA
Creator
Subject
Language
eng
Summary
Under Subdiv 230-E of the Income Tax Assessment Act 1997 (Cth), a taxpayer may elect to apply hedging treatment to holdings of financial arrangements which are in a designated hedging relationship for accounting purposes. The election also covers other situations, including hedges of currency risks in relation to anticipated dividends from overseas subsidiaries. This article examines the character-matching aspects of the hedging election, the effect of which is to match the character of the gain or loss attributable to the hedging financial arrangement with the character of the underlying hedging item. By way of an extended worked example, the article provides a close examination of the issues raised by a hedging transaction, applying the core taxation of financial arrangements (TOFA) rules and the hedging election. In the author's view, there is a need to resolve some of the issues exposed by the example, both the legislative arrangements and finalisation of the Commissioner's views
Citation source
In: The tax specialist. - Sydney. - Vol. 15 (2012),
http://library.link/vocab/creatorName
Poole, M
Language note
English
http://library.link/vocab/subjectName
  • TOFA
  • hedging transaction
  • swap
  • accounting
  • foreign exchange gains and losses
Label
A question of attribution problems with the hedging election under TOFA
Instantiates
Publication
Label
A question of attribution problems with the hedging election under TOFA
Publication

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