Exposure Draft Tax Laws Amendment (Foreign Source Income Deferral) Bill (No. 1) 2010

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On 18 December 2009, the Assistant Treasurer released for public consultation the exposure draft legislation that will give effect to the decision to repeal the foreign investment fund (FIF) and deemed present entitlement (DPE) rules.

The repeal of the FIF and the DPE rules was announced in the 2009-10 Budget as part of wider reforms to Australia's foreign source income anti-tax-deferral (attribution) rules.

Remaining reforms to the controlled foreign company, transferor trust rules and the anti-roll-up rule are still being developed.

Making a submission

Interested parties are invited to comment on the exposure draft Bill. While submissions may be lodged electronically or by post, electronic lodgement is preferred. For accessibility reasons, please submit responses sent via email in a Word or RTF format. An additional PDF version may also be submitted.

All information (including name and address details) contained in submissions will be made available to the public on the Treasury website unless you indicate that you would like all or part of your submission to remain in confidence. Automatically generated confidentiality statements in emails do not suffice for this purpose. Respondents who would like part of their submission to remain in confidence should provide this information marked as such in a separate attachment. Legal requirements, such as those imposed by the Freedom of Information Act 1982, may affect the confidentiality of your submission.

Closing date for submissions: Friday, 5 February 2010

Address written submissions to:
Attribution Review Unit
International Tax and Treaties Division
The Treasury
Langton Crescent
PARKES ACT 2600

Fax: 6263 4352

Email: fsiattribution@treasury.gov.au

For enquiries, please call Kishma Dillon (02) 6263 3398.

Documents Available:

 Acrobat (PDF)

 Microsoft Word (RTF)

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