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Edited version of your written advice
Authorisation Number: 1012678754068
Ruling
Subject: Subdivision 124-M Rollover
Question 1
Will Unitholder 1 be regarded as a significant stakeholder or common stakeholder pursuant to section 124-783 of the Income Tax Assessment Act 1997 (ITAA 1997)?
Answer
Yes
Question 2
Will any of the following Unitholders (x8) be regarded as a significant stakeholder or common stakeholder pursuant to section 124-783 of the ITAA 1997?
Answer
No
Question 3
Will the first element of the cost base and reduced cost base of Replacement Entity in the Original Entity units it acquires from Unitholder 1 be determined pursuant to subsection 124-782(1) of the ITAA 1997?
Answer
Yes
Question 4
Will the first element of the cost base and reduced cost base of Replacement Entity in the Original Entity units it acquires from the Unitholders (x8) be determined pursuant to Divisions 110 and 112 of the ITAA 1997?
Answer
Yes
This ruling applies for the following periods:
the year ended 30 June 20xx
The scheme commences on:
during the year ended 30 June 20xx
Relevant facts and circumstances
The taxpayer, the Replacement Entity, applied for a private ruling in connection with a corporate group restructure under which the Replacement Entity is interposed between the Original Entity and its unitholders.
Relevant legislative provisions
Income Tax Assessment Act 1997
Subdivision 124-M
Division 110
Division 112
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