Document ID: chunk:federal_register_of_legislation:C2025C00029:section:7:p1
Version: federal_register_of_legislation:C2025C00029
Segment Type: section
Provision Reference: s 7 (pt 1/11)
Character Range: 7523826–7526892

7               (a) a foreign resident pursuing in Australia a course of study or training; and                                                                           your *ordinary income, and your *statutory income, by way of a scholarship, bursary, or other educational allowance, provided by the Commonwealth  none
                (b) in Australia for the sole purpose of pursuing that course

Subdivision 842‑I—Investment manager regime

Guide to Subdivision 842‑I

842‑200  What this Subdivision is about

      This Subdivision sets out rules about the taxation of some foreign residents (known as IMR entities) that invest into or through Australia.
      Income and capital gains from IMR financial arrangements are not subject to Australian income tax. Deductions and capital losses from IMR financial arrangements are disregarded for the purposes of this Act.

Table of sections

Object of this Subdivision
842‑205 Object of this Subdivision

IMR concessions
842‑210 IMR concessions apply only to foreign residents etc.
842‑215 IMR concessions
842‑220 Meaning of IMR entity
842‑225 Meaning of IMR financial arrangement

IMR widely held entities
842‑230 Meaning of IMR widely held entity
842‑235 Rules for determining total participation interests for the purposes of the widely held test
842‑240 Extended meaning of IMR widely held entity—temporary circumstances outside entity's control

Independent Australian fund managers
842‑245 Meaning of independent Australian fund manager
842‑250 Reductions in IMR concessions if independent Australian fund manager entitled to substantial share of IMR entity's income

Object of this Subdivision

842‑205  Object of this Subdivision
  The object of this Subdivision is to encourage particular kinds of investment made into or through Australia by some foreign residents that have wide membership, or that use Australian fund managers.

IMR concessions

842‑210  IMR concessions apply only to foreign residents etc.
 (1) This Subdivision applies only for the purposes of working out the assessable income of an entity (the foreign entity) that:
 (a) is a foreign resident; and
 (b) is not a trust or partnership.
 (2) Despite subsection (1), this Subdivision applies in relation to a partnership or trust, to the extent necessary to work out an amount included in the assessable income of the foreign entity.
Note 1: This Subdivision applies, for example, in working out the net income of a partnership or trust, to the extent necessary to work out the assessable income, attributable to that partnership or trust, of a partner or beneficiary who is a foreign resident.
Note 2: This Subdivision could operate in relation to an entity (if it is a partnership or trust) and/or one or more partnerships or trusts interposed between the entity and the foreign resident.

842‑215  IMR concessions

Concessions relating to IMR financial arrangements
 (1) The following consequences apply to an *IMR entity for an income year in relation to an *IMR financial arrangement if the requirements of subsection (3) or (5)