CFM9440 - Taxing forex: matching under Disregard Regulations: trading assets
Restrictions on assets that can be matched
This guidance applies to periods of account beginning on or
after 1 January 2005
Regulations 3 and 4 permit the liability or derivative
contract to be matched to shares, ships or aircraft – a ship
or aircraft may in some cases be accounted for as a foreign
operation. But matching under regulation 3 or 4 is not permitted
where the shares, ships or aircraft are assets held on trading
account. If a profit on the sale of the assets would be a profit of
the trade the regulations cannot apply to disregard the exchange
gain or loss on the liability or derivative matching the asset.
