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Edited version of private advice
Authorisation Number: 1052178102924
Date of advice: 07 November 2023
Ruling
Subject: CGT- exempt income
Question 1
Is the income of the Fund assessable income under subsection 6-5(3) of the Income Tax Assessment Act 1997 (ITAA 1997)?
Answer
No.
Question 2
Is the income of the Fund assessable income under subsection 6-10(5) of the ITAA 1997?
Answer
No.
Question 3
Is a net capital gain made by the Fund assessable income pursuant to section 102-5 of the ITAA 1997?
Answer
No.
Question 4
Are gains made by the Fund from financial arrangements assessable income under subsection 230-15(1) of the ITAA 1997?
Answer
No.
Question 5
Are gains from the disposal or redemption by the Fund of traditional securities assessable income under subsection 26BB(2) of the Income Tax Assessment Act 1936 (ITAA 1936)?
Answer
No.
Question 6
Is the income of the Fund assessable income under subsection 97(3) of the ITAA 1936?
Answer
No.
Question 7
Is the Fund liable to withholding tax under section 128B of the ITAA 1936 on interest, dividend or royalty income it derives from Australia?
Answer
No.
Question 8
Is the Fund liable to withholding tax pursuant to section 840-805 of the ITAA 1997?
Answer
No.