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Published on 11 Feb 09
by NATIONAL DIVISION, THE TAX INSTITUTE
This paper covers the application of the TOFA hedging method to hedging of net investments in foreign operations, exempt dividend income and interest rate hedges through worked examples to illustrate:
identification of the appropriate hedged item
the contemporaneous documentation required
how effectiveness is tested
what the different book and tax treatment means for the ineffective portion
other differences between book and tax treatment
what happens when things change: effectiveness, consolidation and accounting changes.
Julian Humphrey FTIA has 12 years experience with the KPMG Banking & Finance Tax Practice. He works primarily with
international banks and financial services companies operating in Australia providing corporate income tax services. Julian’s
areas of expertise includes the taxation of banks and bank branches, the taxation of financial arrangements and retail financial
products as well as Australia’s offshore banking regime. He is a regular participant in consultation with Government on
Australia’s tax reform proposals affecting Australian financial institutions. Current at 9 February 2009Current at 18 May 2009
The Tax Institute is a Recognised Tax Agent Association (RTAA) under the Tax Agent Services Regulations 2009.
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