Miscellaneous 2013

The investment manager regime so far

Source: The Tax Specialist Journal Article

Published Date: 1 Feb 2013


The investment manager regime (IMR) is concerned with the taxation treatment of returns, gains, losses and deductions on certain investments of widely held foreign funds. The regime is being implemented in three stages. The first two elements, the so-called “conduit income” measures and the “FIN 48” transitional measure, have been enacted by the Tax Laws Amendment (Investment Manager Regime) Act 2012 (Cth). The third element is at the consultation stage. This article first traverses the history leading to the implementation of the IMR, in order to give it context and to attempt to explain its rationale.

The article then proceeds to a detailed examination and analysis of the legislation enacted to date. Some observations are made on the putative rules and modifications to finalise the regime. An Appendix details recommendations made by the Board of Taxation, the government’s responses and the author’s comments on issues raised by those recommendations and responses.

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Miscellaneous 2013

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