This Draft TD, issued on Wed 23.4.2014, states that forex realisation event 4 happens to the debtor under s 775-55(1) of the ITAA 1997 on repayment of a loan taken out prior to the effective date of a choice to use the applicable functional currency and denominated in the same non-AUD currency that later becomes the applicable functional currency.
DATE OF EFFECT: When the final Determination is issued, it is currently proposed to apply both before and after its date of issue.
COMMENTS are due by 23 May 2014. ATO contact: Erin Gordon – Tel: (08) 9268 5353; Fax: (08) 9268 5250; Email: erin.gordon@ato.gov.au.
[LTN 76, 23/4/14]