Who is subject to tofa

The Chemical Company 44 Southwest Ave. This website uses cookies so that we can provide you with the best user experience possible. Cookie information is stored in your browser and performs functions such as recognising you when you return to our website and helping our team to understand which sections of the website you find most interesting and useful.

Strictly Necessary Cookie should be enabled at all times so that we can save your preferences for cookie settings. Skip to content. Categories: Acids , All Products , Mining. Description Description Low sulfur tall oil fatty acid TOFA is designed specifically for the fuel segment as a diesel fuel additive. Error file size too large The uploaded file extension not valid.

Which product are you interested in? Name required. Email required. Bill payments can be made in person, dropped off in one of our payment drop boxes at our office or paid by credit card over the phone. Office hours are Monday-Friday, a. Do you have a fever? Do you currently have a cough or sore throat? Have you traveled internationally within the last 14 days? Have you been in contact with someone with known or suspected Covid? Toggle navigation. The only real limitation on the flexibility afforded by the choice of accruals methods is that any manner used must then be used consistently for all remaining years for the relevant arrangement and for all other financial arrangements of a similar nature.

There is flexibility as to how Purple may approach this and what compounding periods it may use. Assuming it chooses to accrue using an effective interest rate method over quarterly compounding periods, the loss it accrues in each quarter will be:. Balance start. Accrued loss.

Cash flows. Balance end. Adjustments under the compounding accruals method. Over time, if there is any difference between:. Further, if there is a material change affecting the amount, value or timing of a financial benefit prior to it becoming payable, the gain or loss being accrued is required to be re-estimated and appropriate adjustments made.

Finally, if there is a material change to the terms and conditions or circumstances affecting a financial arrangement, whether or not its gains and losses should be subject to the compounding accruals or realisation methodologies must be reassessed.

The realisation method. Where some or all of the gains and losses from a financial arrangement are not sufficiently certain, those gains and losses are accounted for under the realisation method.

Under this method, a gain or loss determined as described above by the appropriate offsetting of cost and proceeds is recognised when:. As explained above, Efficient does not have any sufficiently certain gains and losses under its swap arrangement. Based on the facts set out above, Efficient would realise gains and losses in every swap period at the earlier of when the last of each relevant swap amounts for a period became due or was paid.

Assuming the swap amounts were paid when due, Efficient would make the following gains and losses from its swap financial arrangement under the realisation method as calculated above :. The balancing adjustment. In addition to the compounding accruals and realisation methods, a gain or loss may be determined under the balancing adjustment provisions where all the rights and obligations under a financial arrangement ceases or some or all of a financial arrangement is disposed of where the economic effect is also that there has been a disposal.

In a general sense, the balancing adjustment will be the difference between:. If a gain or loss would have otherwise been recognised under another method such as accruals or realisation at this time, the balancing adjustment takes precedent and the gain or loss is not claimed twice. However, the last gain otherwise recognised under the realisation method does not arise until the last of the swap payments becomes due.

As it has been assumed that each swap payment will be paid when due, this will also be the time at which all rights and obligations under the financial arrangement cease and a balancing adjustment occurs. This is of little practical consequence. Under this method, the last accrual amount was taken into account on 30 September and payment was not made until 1 October technically 1 October is the last accrual period but being only 1 day rounding means that no amount is recognised under compounding accruals for that one day period.

Under the method statement there will be no gain or loss to bring to account under the balancing adjustment as the total loss from the arrangement has been appropriately accounted for under the compounding accruals method. Taxation of gains and losses. Gains and losses as determined in the manner set out above, that are made by taxpayers subject to proposed Division from relevant financial arrangements to which proposed Division applies, will be on revenue account for tax purposes.

With very few exceptions, gains from financial arrangements are assessable, and losses are deductible to the extent to which they were made in gaining or producing assessable income or in carrying on a business for the purposes of gaining or producing assessable income. Efficient will have the following gains and losses from the swap arrangement: Purple will be allowed a deduction from its assessable income in respect of the following losses from the deferred purchase agreement: If no elective tax-timing methods are applicable, gains and losses from these financial arrangements will be brought to tax on revenue account under either:.

Although outside the scope of this paper, the elective tax timing methods that may be available to take account of a gain or a loss from a financial arrangement are the fair value method provided for in proposed Subdivision C, the foreign exchange retranslation method provided for in proposed Subdivision D, the hedging financial arrangement method provided for in proposed Subdivision E and the method of relying on financial reports provided for in proposed Subdivision F of the ITAA , as set out in item 1 of Schedule 1 to the TOFA Bill.

See paragraph 2. See also paragraphs 4. See proposed sections and of the ITAA See proposed section of the ITAA which defines what an equity financial arrangement is; plus proposed paragraph 2 e and proposed subsections 1 and 1 of the ITAA , which prevent the accruals, realisation, retranslation and hedging methods from applying to equity financial arrangements.

See proposed subsection of the ITAA and paragraph 2. See proposed subsection 1 and proposed section of the ITAA See proposed paragraphs 2 b , c and d of the ITAA For more detail refer to paragraphs 2. See proposed paragraphs 2 b , c and g of the ITAA See proposed paragraph 2 e of the ITAA See proposed paragraph 2 f and proposed subsection 3 of the ITAA See proposed paragraph 2 a of the ITAA See proposed subsection 1 of the ITAA See note to proposed subsection 1 of the ITAA and paragraphs 2.

Proposed subsection 1 of the ITAA See also paragraphs 2. Proposed subsection 2 of the ITAA Proposed subsection 13 of the ITAA Proposed section of the ITAA See proposed paragraph 2 e and proposed subsections 1 and 1 of the ITAA preventing the application of the accruals, realisation, retranslation and hedging methods to equity financial arrangements ; proposed subsection 1 and proposed paragraph 1 c of the ITAA providing the requirements under the fair value method that the taxpayer not be the issuer of the equity interest and that the equity financial arrangement be fair valued through profit and loss ; and proposed subsection 1 and proposed paragraph 1 d of the ITAA providing similar requirements under the financial reports method that the taxpayer not be the issuer of the equity interest and that the equity financial arrangement be fair valued through profit and loss.

In addition, even if an equity interest meets these requirements and is subject to proposed Division of the ITAA , franked distributions on such an equity interest will continue to be dealt with outside this proposed Division: See proposed subsections 2 and 2 of the ITAA Because Division only has limited application in respect of equity interests, necessitating the application of an elective tax-timing method, equity financial arrangements are not discussed in the remainder of this paper.

Namely authorised deposit-taking institutions, securitisation vehicles and entities required to register under the Financial Sector Collection of Data Act or who would be required to so register if they were a corporation: see proposed paragraph 2 a of the ITAA See proposed subparagraph 1 a ii and subsection 2 of the ITAA See proposed paragraph 1 a and subsection 2 of the ITAA See proposed subsections 1 , 4 and 5 of the ITAA The double negatives in this provision outlining which financial arrangements of individuals and entities below the relevant turnover thresholds difficult to decipher, but essentially the only financial arrangements it covers are qualifying securities having more than 12 months to run at the time of acquisition by the relevant taxpayer.

See proposed subsections 4 and 5 of the ITAA Per subitems 98 2 and 3 of Schedule 1 to the TOFA Bill Note also that whilst it applies to a different election, the inference from paragraph As noted above, the inference from paragraph