Published on 24 May 07
by NEW SOUTH WALES DIVISION, THE TAX INSTITUTE
The foreign exchange rules remain a mystery to many advisors. This paper examines, through a series of case studies, the anomalous and inconsistent outcomes that can arise when applying these rules to common financing methods including:
- foreign currency denominated loans and RPS
- AUD denominated loans coupled with a foreign currency swap
The case studies also consider certain issues arising from investing in foreign currency denominated investments, including:
- dividend hedging
- investments that are subject to “calls”.
Tim is a Director of Greenwoods & Herbert Smith Freehills, based in the Sydney office. He focuses on the resources and financial services industries, advising clients on a wide range of income tax matters, including mergers and acquisitions, capital management, cross-border dealings, market value issues, audits and tax litigation. Tim has worked on a range of matters involving Part IVA advice, rulings and disputes.
- Current at
22 June 2017