16 Dec 09 Uncommercial offshore superannuation trusts - TA 2009/19
On 15 December 2009, the ATO issued Taxpayer Alert TA 2009/19 entitled "Uncommercial offshore superannuation trusts". The Taxpayer Alert describes arrangements that use offshore trust structures (purported to be superannuation funds) in an attempt to shift funds into Australia in a concessionally taxed manner or substantially defer the time at which such amounts are subject to tax in Australia.
The ATO is considering a number of superannuation regulatory issues (the in-house asset provisions, and the sole purpose test under s 62 of the SIS Act) and taxation issues (19 in all).
For a copy of TA 2009/19, go here