A currency exchange loss under Division 3B of the Income Tax Assessment Act 1936 (Cth) can be realised without an actual exchange of foreign and Australian currencies. The discharge of a foreign currency debt by the tender of a promissory note obtained through Australian dollar expenditure (or the use of an Australian dollar-denominated asset) is sufficient to constitute realisation. The High Court's reference to an 'exchange transaction' in ERA HC was illustrative, not a definitional requirement of Division 3B.
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