A joint submission from the Taxation Institute of Australia, the Institute of Chartered Accountants in Australia, CPA Australia, Corporate Tax Association of Australia and Taxpayers Australia regarding Draft Taxation Determination TD 2004/D76 Income tax: for the purposes of Division 974 of the Income Tax Assessment Act 1997, does an issuing company have an effectively non-contingent obligation to provide a financial benefit by way of periodic interest returns on an interest bearing convertible note from the time that it can be converted at the issuing company's option into ordinary shares in that company?
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