TOFA isn’t just for people who trade hybrid derivatives over pork bellies in Botswana. In fact, it will affect many common transactions by ordinary tax payers. This paper examines:
- where TOFA will supercede current law
- what happens to interest income and expense, borrowing costs and the rest?
- how TOFA overlays current law and what that means
- what the carve out for small business and individuals means, and how it will operate.