The Taxation of Financial Arrangements (TOFA) Legislation: Is There Work Left to be Done?

AUSTRALIAN BUSINESS TAX REFORM IN RETROSPECT AND PROSPECT, Chris Evans and Richard Krever, eds., Forthcoming

26 Pages Posted: 1 Oct 2009

Abstract

The paper offers some general comments on certain of the broad design features of the Australian taxation of financial arrangements (TOFA) legislation. More particularly, the paper compares these features of the TOFA legislation with those of a comprehensive accrual regime. Although the TOFA legislation is broadly consistent with such a regime, it has some unique features that set it apart.

Keywords: financial instruments, debt-equity boundary, debt-derivative boundary, market-value accounting, hedge accounting

JEL Classification: H20, H25

Suggested Citation

Edgar, Timothy, The Taxation of Financial Arrangements (TOFA) Legislation: Is There Work Left to be Done?. AUSTRALIAN BUSINESS TAX REFORM IN RETROSPECT AND PROSPECT, Chris Evans and Richard Krever, eds., Forthcoming, Available at SSRN: https://ssrn.com/abstract=1480681

Timothy Edgar (Contact Author)

Osgoode Hall Law School ( email )

4700 Keele Street
Toronto, Ontario M3J 1P3
Canada

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