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Draft Taxation Determination TD 2007/D16 considered the potential application of section 177EA of the Income Tax Assessment Act 1936 to a particular type of convertible note that has certain features, including a 'dollar value' conversion mechanism (that are explained in the draft Determination).
TD 2007/D16 is being replaced by TR 2008/D8. To the extent that our views in TD 2007/D16 still apply, they have been incorporated into TR 2008/D8 which issued today.
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