To allow the foreign investment fund (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
- 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 general insurance company
- an interest in a foreign company engaged in certain real property activities
- an interest in foreign trusts
- an interest of $50,000 or less
- visitors to Australia
- employer-sponsored foreign superannuation
- an interest in a FIF that is trading stock
- an interest in a multi-industry foreign company
- underwriting members of Lloyd's
- a balanced investment portfolio in FIFs
- an interest in certain FIFs resident in the USA
- complying superannuation funds
- certain investments in FIFs that primarily engage in managing funds.