(a) you cease to be an Australian resident at a particular time (the residence change time ); and
(b) you have a * financial arrangement at the residence change time; and
(c) at the residence change time you expect that any gains and losses you make from the arrangement after that time will not be assessable or deductible under this Division.
(2) You are taken for the purposes of this Division:
(a) to have disposed of the arrangement just before that time for its fair value just before that time; and
(b) to have acquired the arrangement again at the residence
change time for its fair value at that time.