The Australian Taxation Office has published draft Taxation Determination (TD) 2019/D10 - Income tax: can capital gains be included under subparagraph 770-75(4)(a)(ii) of the Income Tax Assessment Act 1997 when calculating the foreign income tax offset limit?
Comments on TD 2019/D10 are due by 8 November 2019.
---
Ruling
1. No. Capital gains are not included under subparagraph 770-75(4)(a)(ii) of the Income Tax Assessment Act 1997 when calculating the foreign income tax offset limit.
…