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Edited version of your written advice
Authorisation Number: 1012699056985
Ruling
Subject: Capital gains tax
Question and answer:
Is the first element of the cost base of your overseas CGT assets the market value of those assets on the day you become an Australian resident for taxation purposes?
Yes.
This ruling applies for the following period:
1 July 2014 to 30 June 2015.
The scheme commenced on:
1 July 2014.
Relevant facts and circumstances:
You are a foreign national.
You became an Australian resident for taxation purposes.
You own CGT assets overseas.
You acquired your ownership interest in all your overseas CGT assets on or after 20 September 1985.
You may sell some or all of your overseas assets in the future.
Relevant legislative provisions:
Income Tax Assessment Act 1997 - Section 855-45
Reasons for decision
Special rules apply to determine the first element of the cost base of capital gains tax (CGT) assets located overseas that are owned by individuals who become Australian residents for taxation purposes.
The first element of a CGT asset that is held outside of Australia by a person who becomes an Australian resident for taxation purposes is the market value of the asset on the day they become an Australian resident for tax purposes.
You have an ownership interest in CGT assets located overseas and you acquired your ownership interest in all those assets on or after 20 September 1985.
You became an Australian resident for taxation purposes.
The first element of the cost base of your overseas CGT assets will be the market value of those assets on the day you became an Australian resident for taxation purposes.