Published on 14 Oct 05
by TASMANIAN DIVISION, THE TAX INSTITUTE
Many practitioners believe that the TOFA reforms involve issues that are the domain of the 'Big end of town'. However, the reality is that these reforms can also impact how SMEs are required to treat certain transactions for tax purposes. This paper addresses:
- what is the current status of TOFA reforms:
- debt/equity 'at call loans'
- foreign exchange gains and losses
- illustrative examples
- carve out rules for small and SME clients
- likely direction of future TOFA reforms around financial assets and liabilities.
Gary Christie is head of Deloitte’s National Tax technical area. Gary provides advice on a wide variety of transactions as well as undertaking the internal tax technical training and quality assurance reviews for Deloitte nationally. Gary is also heavily involved in a range of consultation on new tax measures with both Treasury and the ATO. Prior to joining Deloitte, Gary spent over 25 years in the ATO mainly in the Large Business and International segment, the last few years occupying the role of Assistant Commissioner. He also headed up the National Energy and Resource segment and was critically involved in the management and resolution of large audit cases and disputes. Gary has an excellent working relationship with the ATO and an in-depth understanding of its administrative processes.
- Current at
23 September 2013