Retrospective amendments to allow the reduction of consideration from the disposal of an asset
Tax Laws Amendment (Foreign Source Income Deferral) Bill (No. 1) 2010 was introduced to Parliament on 13 May 2010. When enacted, the changes will amend the income tax law to allow the consideration for the disposal of assets held on revenue account (as opposed to just interests held on capital account) to be reduced by associated FIF and CFC income which has previously been attributed. These changes will have effect to tax assessments for the 2006-07 income year and any subsequent income years.
When enacted this bill will also repeal the FIF and deemed present entitlement rules, with general application from the 2010-11 income year. The Government has announced that it will introduce into Parliament legislation to create a specific anti-avoidance rule as a replacement for the FIF and deemed present entitlement rules.