Exemption for attributable taxpayers

The existing foreign source income measures consist of two components-the CFC measures and the transferor trust measures. These measures attribute specified income and gains of foreign companies and trusts to certain Australian residents-known as attributable taxpayers. The FIF measures may overlap with the foreign source income measures. Where this occurs the foreign source income measures apply and, in general, the FIF measures will not apply. However, the FIF measures do apply in working out the income of a CFC, CFT or transferor trust which holds an interest in a FIF. [SECTIONS 493 and 494]