ATO Private Ruling Database - Forex - Tax Matrix

1 1 Ruling NoSubjectLinkQuestions45095 Forex Gains and Will any Forex realisation gains and losses made in respect of your foreign currency denominated cheque account be disregarded?2. Is the foreign currency denominated dividend paid into your foreign currency cheque account during the 2003-04 income year translated into Australian dollars at the exchange rate prevailing at the time it was paid?3. Are you entitled to a deduction for the expense you incurred in obtaining a rate of exchange used to translate the value of your foreign currency denominated income?45250 Application of foreign currency ( Forex ) rules to repayment of foreign currency denominated the Forex realisation gain or loss you made on repayment of the principal owing on your foreign currency denominated loan be recognised under the new Forex provisions?

2 45619 Forex realisation gains and losses on loan used to gain non-portfolio To the extent that the foreign currency borrowings were incurred for the purpose of deriving non-assessable non-exempt income:- Will any Forex realisation loss made by the taxpayer on the complete or partial repayment of the borrowings, as described in the subject of the Ruling , be disregarded under subsection 775-35(2) of the Income Tax Assessment Act 1997 (ITAA 1997)?- Will any Forex realisation gain made by the taxpayer on the complete or partial repayment of the borrowings, as described in the subject of the Ruling , be non-assessable non-exempt income under section 775-25 of the ITAA 1997?47530 foreign exchange Translation Rules - Dividends - Interest - foreign Tax Credits- Capital Gains/ Can you use the exchange rate prevailing at the end of the income year to convert your foreign currency denominated dividend income derived during that income year to Australian dollars?

3 2. Can you use the exchange rate prevailing at the end of the income year to convert your foreign currency denominated interest income derived during that income year to Australian dollars?3. Can you use the exchange rate prevailing at the end of the income year to convert the foreign tax credits attributed to you during that income year to Australian dollars?4. Can you use the exchange rate prevailing at the end of the income year to convert any foreign capital gains and capital losses you made during that income year to Australian dollars?ATO Private Binding RulingsForeign exchange ( Forex )Current to 19/11/10. Search Subject > foreign exchange & Subject > Forex2 Ruling NoSubjectLinkQuestionsATO Private Binding RulingsForeign exchange ( Forex )Current to 19/11/10. Search Subject > foreign exchange & Subject > Forex51789 Index Options Trading, exchange Rate & foreign exchange Will the options trading income be included as my assessable income (having regard to the point set out in the application that consideration be given that, up to 30 June, 2004, such income be treated as being derived from a hobby)?

4 2. Which day s daily currency exchange rate should be used to translate options trading income into Australian currency in order to calculate the rulee's assessable income? 3. Is a deduction allowable for the proportion of the ISP monthly subscription fee that relates to the options trading activities?4. Is a deduction allowable for the proportion of the internet option information service subscription fee that relates to the options trading activities? 5. Is a deduction allowable for the proportion of the telephone rental that relates to the options trading activities?6. Is a deduction allowable for the proportion of the telephone call charges that relate to the options trading activities?7. Is a deduction allowable for the proportion of the electricity charges that relate to the options trading activities?

5 8. Is a deduction allowable for the proportion of the depreciation deducti9. Will any Forex realisation gain which is made by the rulee be disregard52878 foreign exchange gains or losses - traditional Will the gains or losses that you make on disposal of your bonds be assessable income or allowable deductions respectively?2. Are you entitled to a deduction for the telephone, postage and stationery expenses you have incurred in managing your investments in the bonds?54284 foreign exchange Gain/Loss & Whether an exchange gain that would be made on the refinancing of a US$ borrowing of ABC Finance with a Euro denominated borrowing is on capital In the event the Commissioner should rule that he will not seek to tax such foreign exchange gain under section 6-5 of the Income Tax Assessment Act 1936 (ITAA 1936).

6 55944 Capital gains tax: foreign exchange loss on redemption of fixed interest a loss resulting from the redemption of a traditional security denominated in a foreign currency be determined in that foreign currency and then translated into Australian dollars at the exchange rate prevailing at the date of redemption?55945 Capital gains tax: foreign exchange loss on redemption of fixed interest a loss resulting from the redemption of a traditional security denominated in a foreign currency be determined in that foreign currency and then translated into Australian dollars at the exchange rate prevailing at the date of redemption?57843 foreign exchange Gains and Ruling concerned a request from a resident rulee in relation to the taxation consequence of a domestic operating lease arrangement under Income Tax Assessment Act 1997 (ITAA 1997).

7 57844 foreign exchange Gains and Ruling concerned a request from a resident rulee in relation to the taxation consequence of a sale and leaseback arrangement under the Income Tax Assessment Act 1997 (ITAA 1997).3 Ruling NoSubjectLinkQuestionsATO Private Binding RulingsForeign exchange ( Forex )Current to 19/11/10. Search Subject > foreign exchange & Subject > Forex59134 Application of Division 775 - Forex Realisation Event 4 Does section 775-55 of the Income Tax Assessment Act 1997 (ITAA 1997) concerning Forex realisation event 4 (FRE 4) happen upon each roll-over that occurs pursuant to clause X of the loan facility contracts?2. If there is a Forex realisation gain or loss arising as a result of FRE 4 applying to an event under the loan facility contracts, is it disregarded under subsection 775-165(4) of the ITAA 1997?

8 3. If the Forex realisation gain or loss is disregarded under subparagraph 775-165(4)(a)(ii) of the ITAA 1997, does subsection 775-165(5) of the ITAA 1997 cause subparagraph 775-165(4)(a)(ii) not to apply?61484 SER and MEC interaction with TOFA - Forex is intended that several entities will form a MEC group from 1 January 2004. On formation of the MEC group, Entity A will become a subsidiary member of the MEC group. Subsequent to the formation date, Entity A made an election pursuant to section 775-150 of Part 4-5 of the Income Tax Assessment Act 1997 (ITAA 1997). Will the election made by Entity A pursuant to 775-150 of Part 4-5 of the ITAA 1997 apply to the financial assets, liabilities, rights and obligations of the MEC Group that were in existence at the formation date?61663 foreign Income- foreign exchange you entitled to a deduction for the foreign exchange losses expected to be incurred, due to fluctuations in exchange rates between the time you deposited the money and the time you made the withdrawal from your foreign bank account?

9 62961 SER and MEC interaction with TOFA - Forex is intended that several entities will form a MEC group. On formation of the MEC group, entity A will become a subsidiary member of the MEC group. Subsequent to the formation date, entity A made an election pursuant to section 775-150 of Part 4-5 of the Income Tax Assessment Act 1997 (ITAA 1997). Will the election made by entity A pursuant to 775-150 of Part 4-5 of the ITAA 1997 apply to the financial assets, liabilities, rights and obligations of the MEC group that were in existence at the formation date?4 Ruling NoSubjectLinkQuestionsATO Private Binding RulingsForeign exchange ( Forex )Current to 19/11/10. Search Subject > foreign exchange & Subject > Forex66347 Investments-deduction-interest- foreign exchange gains and Are you entitled to a deduction for interest incurred as an expense which is in excess of the interest income derived relating to your investment in a bond?

10 2. Are you entitled to a deduction for interest incurred as an expense to the extent of the interest income derived relating to your investment in a bond?3. Where a foreign currency denominated borrowing is repaid in part or in full, is a foreign exchange ( Forex ) realisation gain included in your assessable income and a Forex realisation loss allowed as a deduction?66456 Forex realisation Are you entitled to a deduction for a Forex realisation loss resulting from the transfer of monies from your overseas bank account to your holding account in the year you transferred the funds?2. Are you entitled to a deduction for a Forex realisation loss resulting from the transfer of monies from your overseas bank account to your holding account in a later year of income?68450 Forex realisation gains and Are you entitled to a deduction for a Forex loss as a result of the bank account transactions in connection with your overseas and X bank accounts?