Legislation

TAA 1953 s What this Ruling is about 1 Date of effect 3 Background 4 Example 1 - Restructure from company to discretionary trust 6 Facts 6 No direct income tax consequences from the transfer of assets 11 Setting the tax values of the transferred assets in the hands of the transferee 13 Acquisition times in the hands of the transferee are set 18 Example 2 - Restructure from partnership to company - cost base of shares 24 Facts 24 Tax values of any membership interests issued for the transfer are set 30 Example 3 - Capital loss on shares attributable to transfer of asset 36 Facts 36 Uneconomic losses that are attributable to the transfer are disregarded 40 Example 4 - Transfer of assets that form a small business pool 44 Facts 44 No direct income tax consequences from the transfer of asset 49 Tax values of any membership interests issued for the transfer are set 54 Example 5 - Direct tax consequence - FX loan 58 Facts 58 Other tax consequences are recognised 60 Example 6 - Indirect tax consequence - subsequent debt forgiveness 63 Facts 63 Other tax consequences are recognised 68 Relying on this Ruling This publication is a public ruling for the purposes

ATO documents that consider TAA 1953 s What this Ruling is about 1 Date of effect 3 Background 4 Example 1 - Restructure from company to discretionary trust 6 Facts 6 No direct income tax consequences from the transfer of assets 11 Setting the tax values of the transferred assets in the hands of the transferee 13 Acquisition times in the hands of the transferee are set 18 Example 2 - Restructure from partnership to company - cost base of shares 24 Facts 24 Tax values of any membership interests issued for the transfer are set 30 Example 3 - Capital loss on shares attributable to transfer of asset 36 Facts 36 Uneconomic losses that are attributable to the transfer are disregarded 40 Example 4 - Transfer of assets that form a small business pool 44 Facts 44 No direct income tax consequences from the transfer of asset 49 Tax values of any membership interests issued for the transfer are set 54 Example 5 - Direct tax consequence - FX loan 58 Facts 58 Other tax consequences are recognised 60 Example 6 - Indirect tax consequence - subsequent debt forgiveness 63 Facts 63 Other tax consequences are recognised 68 Relying on this Ruling This publication is a public ruling for the purposes