Published on 09 Oct 09
by VICTORIAN DIVISION, THE TAX INSTITUTE
The TOFA legislation received Royal Assent six months ago and early electing taxpayers may in some cases be already subject to the new rules. There is still time before the first TOFA elections need to be made.
This paper covers a number of practical issues that have become relevant in determining the potential impact of TOFA and is intended to help with your decisions on the various elections available. It includes a practical analysis supported by case studies covering:
a suggested approach to determining the preferable TOFA position
is tax hedging as beneficial as it appears and how is it achieved?
when would you consider the accounting based elections?
TOFA issues still under consultation.
Neil Ward FTI
Neil is a Partner at Deloitte. Neil has more than 25 years experience advising on tax. During this period he has advised on most aspects of corporate taxation both from an Australian
and International perspective. Neil has had significant experience with tax consulting to the banking and finance sector. Neil is
recognised as one of the leading tax advisers on financial arrangements, foreign exchange, thin capitalisation and infrastructure
transactions and has been actively involved in the tax reform of financial arrangements. Current at 01 June 2009
The Tax Institute is a Recognised Tax Agent Association (RTAA) under the Tax Agent Services Regulations 2009.
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