Taxation Ruling

IT 2336W - Notice of Withdrawal

Income tax: treatment of gains from convertible notes

• Please note that the PDF version is the authorised version of this withdrawal notice.

FOI status:

may be released

NOTICE OF WITHDRAWAL

Taxation Ruling IT 2336 is no longer current and is therefore withdrawn.

The Ruling is about the following:

*

former section 26AAA of the Income Tax Assessment Act 1936 (the Act). That section was repealed in 1994;

*

the first limb of section 25A of the Act, which does not apply in respect of the sale of property acquired on or after 20 September 1985. The provisions of Part IIIA of the Act apply from that date;

*

the second limb of section 25A of the Act. Since the amendment to the Act by Taxation Laws Amendment Act (No.3) 1989, any gain on disposal or redemption of a convertible note would be included in the assessable income of the taxpayer by virtue of section 26BB of the Act.

Commissioner of Taxation
25 June 1997

References

ATO references:
NO NAT 97/1896-6

Related Rulings/Determinations:

IT 2336

Legislative References:
ITAA 26AAA
ITAA 25A
TLA(3)