The Australian Taxation Office (ATO) is carefully scutinising the source of hedging gains for the purposes of calculating the foreign income tax offset (FITO) limit in s 770-75 of the Income Tax Assessment Act 1997 (Cth).

Read our summary of the ATO approach to FITOs as set out in Practical Compliance Guideline PCG2016/6 and Taxation Ruling TR 2014/7, here.