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Edited version of your written advice
Authorisation Number: 1012677512613
Ruling
Subject: Subdivision 124-M Rollover
Question 1
Will rollover be available under Subdivision 124-M of the Income Tax Assessment Act 1997 (ITAA 1997) in respect of the taxpayer exchanging their shares in Entity 1 for shares in Entity 2?
Answer
Yes
Question 2
Will a capital gain on the disposal of shares in Entity 1 be disregarded pursuant to section 124-785?
Answer
Yes
Question 3
Will the cost base in Entity 2 shares acquired under the arrangement be equal to the cost base of Entity 1 shares exchanged under the arrangement?
Answer
Yes
Question 4
Will there be any ineligible proceeds as defined in section 124-790?
Answer
No
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, an original interest holder in Entity 1, applied for a private ruling in connection with a corporate group restructure under which a new Entity 2 will be interposed between the original interest holder and Entity 1.
Relevant legislative provisions
Income Tax Assessment Act 1997
Subdivision 124-M