Notice of Rulings 31 August 2022 (Cth)

Notice of Rulings 31 August 2022 The Commissioner of Taxation, Chris Jordan, gives notice by notifiable instrument under subsection 358-5(4) of Schedule 1 to the Taxation Administration Act 1953 of the following public rulings, copies of which can be obtained from ato.gov.au/law

NOTICE OF RULINGS Ruling number Subject Brief description CR 2022/78 Vimy Resources Limited – scrip for scrip roll-over This Ruling sets out the income tax consequences for Australian-resident holders of ordinary shares in Vimy Resources Limited who exchanged their shares for shares in Deep Yellow Limited on 4 August 2022. This Ruling applies from 1 July 2022 to 30 June 2023. CR 2022/79 New World Resources Limited – return of capital by distribution of shares in Koba Resources Limited This Ruling sets out the income tax consequences of the reduction of share capital by New World Resources Limited which was satisfied by the transfer of shares in Koba Resources Limited to the shareholders of New World on 26 April 2022. This Ruling applies from 1 July 2021 to 30 June 2022. PR 2022/7 Bell Equity Lever – instalment receipts This Ruling sets out the Commissioner's view of the consequences of investing in the Bell Equity Lever facility offered by Bell Potter Capital Limited. This Ruling applies from 1 July 2022 to 30 June 2025. PR 2022/8 Bell Geared Equities Investment This Ruling sets out the Commissioner's view of the consequences of investing in the Bell Geared Equities Investment offered by Bell Potter Capital Limited. This Ruling applies from 1 July 2022 to 30 June 2025. TD 2022/12 Income tax: is the source concept in Division 6 of Part III of the Income Tax Assessment Act 1936 relevant in determining whether a non-resident beneficiary of a resident trust, or trustee for that trust, is assessed on an amount of trust capital gain arising under Subdivision 115–C of the Income Tax Assessment Act 1997? This Determination describes when an amount of trust capital gain is assessable to a non-resident beneficiary or trustee. It also describes when a non-resident beneficiary's share of taxable Australian property gains of a non-resident trust and a trustee's share of a capital gain applies. This Determination applies to arrangements entered into before and after its date of issue. TD 2022/13 Income tax: does Subdivision 855-A (or subsection 768-915(1)) of the Income Tax Assessment Act 1997 disregard a capital gain that a foreign‑resident (or temporary‑resident) beneficiary of a resident non‑fixed trust has because of subsection 115-215(3)? This Determination describes when a capital gain that a foreign-resident beneficiary of a resident non-fixed trust has can be disregarded. This Determination applies both before and after its date of issue.