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TOFA and hedging presentation

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Published on 11 Feb 09 by NATIONAL DIVISION, THE TAX INSTITUTE

This presentation 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.

Author profile

Mathew Umina
Mathew is a Tax Director at Rio Tinto. He has been with Rio for four years, with a focus on managing tax risks, disputes, and relationships with revenue authorities. Prior to this Mathew worked at the Australian Taxation Office for 20 years. During his time at the ATO held several senior roles in corporate tax and international areas, as well as the SME and high wealth individuals area. This has included several years working on the design and implementation of the TOFA regime, and more recently as the ATO delegate and Competent Authority to the JITSIC Taskforce in London. - Current at 20 May 2022

 

This was presented at Financial Services Taxation Conference 2009 .

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Individual sessions

Hedging workshop

Author(s):  Julian HUMPHREY

Materials from this session:

TOFA and hedging

Author(s):  Mathew UMINA

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Tax issues in a bear market: Assets side

Author(s):  Allan BLAIKIE

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Tax issues in a bear market: Liabilities side presentation

Author(s):  Patrick BROUGHAN

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Profit attribution to permanent establishments and transfer pricing following the Roche case

Author(s):  Nick HOUSEMAN

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Financial services tax update

Author(s):  Antoinette ELIAS

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Thin capitalisation including the impact of falling asset values

Author(s):  Paul BALKUS,  Daryl CHOO

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Developments in the administration of promoter penalties

Author(s):  Bruce COLLINS

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The capital revenue debate and the managed funds review

Author(s):  Andrew MILLS

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Managing TOFA, implementation and ongoing–Tax Office perspective

Author(s):  Ross BROOKES

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Managing TOFA, implementation and ongoing–The TOFA countdown has begun

Author(s):  Neil WARD

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Annual compliance arrangements

Author(s):  Stephen GREEN

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Superannuation update

Author(s):  Shayne CARTER

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TOFA for the clients of financial institutions

Author(s):  David LINKE

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TOFA–The international dimension

Author(s):  Tony FROST

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Walking the wire-The Australian economy in 2009

Author(s):  Michael BLYTHE

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Further details about this event:

 

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