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An overview of hedging under TOFA paper


This paper covers:

  • what transactions/situations can be hedged?
  • what instruments can be used as hedges?
  • what are the requirements to come within the tax-hedge rules?
  • what are the tax-status and tax-timing matching rules?
  • can tax effective hedging be achieved without resort to the tax-hedge rules?

Author profile:

Author Photo - Tony FROST
Tony Frost FTIA has been a Director with the Sydney office of Greenwoods & Freehills since 2003. Tony has more than 20 years experience in tax, with a focus on financial services and financial transactions. Tony has advised clients on a wide range of tax matters, including innovative financial products, structured finance, mergers and acquisitions, cross-border dealings, transfer pricing, tax audits and negotiations with the Australian Taxation Office. Prior to joining the firm in 2003, Tony had been a Tax Partner for seven years with one of the major international accounting firms. Earlier in his career, Tony spent five years with Westpac Banking Corporation. He has over 20 years experience in tax and has advised clients on a wide range of issues, but with an emphasis on financial products and financial institutions. Tony has had significant involvement in the tax reform process via industry and professional bodies. In particular, Tony has written or coordinated many submissions over the last 18 years for the banking industry, including on the TOFA reforms. Tony lectures on the taxation of financial transactions in the Masters of Law course at the University of Sydney and is a regular speaker and writer on this subject for the Taxation Institute and other organisations.
Current at 11 February 2009 Current at 23 February 2009 Click here to expand/collapse more articles by Tony FROST.


This was presented at Practical Aspects of Accruals and Hedging Under the TOFA Regime .

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Individual sessions

How TOFA fits into the tax net

Author(s):  Gavin MARJORAM

Materials from this session:

Fundamentals that need to be considered

Author(s):  Gavin MARJORAM

Materials from this session:

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