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Practical TOFA considerations for corporates paper 15112009


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 elections re TOFA need to be made.

This paper covers a number of practical issues that are relevant in determining
the potential impact of TOFA and is intended to help with your decisions on the various elections available. This will be a practical analysis supported by case studies covering the following areas.

  • 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.

Author profile:

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 Click here to expand/collapse more articles by Neil WARD.
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