To allow the FIF measures to focus on cases that provide the greatest opportunity for deferral of Australian tax, there are a number of exemptions from FIF taxation:
- attributable taxpayers under the CFC or the transferor trust measures
- an interest in an active business
- an interest in a foreign bank
- an interest in a foreign holding company of a foreign bank
- an interest in a foreign life insurance company
- an interest in a foreign holding company of a foreign life insurance company
- an interest in a foreign general insurance company
- an interest in a foreign holding company of a foreign general insurance company
- an interest in a foreign company engaged in certain real property activities
- an interest in a foreign holding company of a foreign company engaged in certain real property activities
- an interest of $50,000 or less
- temporary residents
- an interest in an employer-sponsored foreign superannuation fund
- an interest in a FIF that is trading stock
- an interest in a foreign company principally engaged in several activities
- an interest in a foreign holding company of a foreign mixed activity company
- an interest in a premium trust fund by an underwriting member of Lloyd's
- a balanced investment portfolio in FIFs
- an interest in certain FIFs resident in the United States
- complying Australian superannuation entities and interests in certain assets of life insurance companies and certain fixed trusts.