*TR 2014/7 – Foreign Income Tax Offset (FITO): source of hedging transactions – source of hedging transactions for the purpose of the s770-75 FITO limit [30]
This Ruling, released on Wed 10.12.2014, deals with the application of s770-75 of the ITAA 1997 (foreign income tax offset (FITO) limit) to an Australian resident taxpayer deriving gains and losses from foreign currency hedging transactions undertaken to mitigate the foreign currency fluctuation risk attached to the market value of a portfolio of assets. Broadly,…