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Taxation Institute Tax Counsel, Tamera Cockerill ATIA, Tony Frost FTIA (Greenwoods & Freehills) and Matt Osmond FTIA (PwC) represented the Taxation Institute at the TOFA Working Group meeting on Tuesday, 20 July 2010. The Working Group discussed a number of hedging issues, including the ATO's draft fact sheet on sample wording for tax hedging documentation. The fact sheet should be finalised soon and will be available on the ATO's website. The Working Group discussed the ATO's views on hedging of firm commitments to acquire trading stock, and the possible need for legislative changes to ensure the policy objectives are met. Finally, the TOFA treatment of securitisation transactions were discussed at length. The ATO is continuing to develop its views in this area and is continuing to work on a discussion paper. The ATO will be releasing the draft paper to members of the Working Group in due course.

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