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Edited version of your written advice
Authorisation Number: 1013096894068
Date of advice: 27 September 2016
Ruling
Subject: FOREX Realisation Events
Question 1
Does the redenomination from Foreign Currency to Australian Dollars of loans entered into by the entity result in a forex realisation event 4 (FRE4) happening under Division 775 of the Income Tax Assessment Act 1997 (ITAA 1997)?
Answer
Yes.
Question 2
If the answer to Question 1 is "Yes", will the forex realisation gain made as a result of the FRE 4 happening be non-assessable non-exempt income pursuant to section 775-25 of the ITAA 1997 based upon its nexus to deriving dividend income that would have been non-assessable non-exempt income in the hands of the entity by virtue of section 23AJ of the Income Tax Assessment Act 1936?
Answer
Yes.