FIF attribution accounts record the income attributed or distributed to you from each of your interests in a FIF or FLP. They allow you to claim exemptions for FIF income previously attributed to you. Therefore, they operate to prevent double taxation where - after being subject to FIF taxation under the FIF measures - you later:
- receive a distribution of income or gains from a FIF or FLP [section 23AK]
- dispose of the interest in a FIF or FLP [section 613], or
- use a FIF loss to reduce assessable income. [sections 532 and 533]
Keep records of:
- income attributed to you from a FIF or FLP
- income distributed to you by a FIF or FLP either directly or through interposed FIF attribution account entities - defined below under Terminology
- the amount of any reduction of consideration you can claim on disposal of an interest in the FIF or FLP, and
- the amount of any deduction from assessable income you claim because of a FIF loss.
Attribution accounts operate on the simple basis of credits and debits.
In the FIF measures:
- a credit is referred to as a FIF attribution credit
- a debit is referred to as a FIF attribution debit.
Where the amount of FIF attribution credits in an attribution account is more than the amount of FIF attribution debits, the excess is referred to as a FIF attribution surplus. This chapter explains these concepts and the way in which double taxation is avoided.
Attribution accounts enable you to keep track of amounts attributed to you under the FIF measures and amounts distributed to you from the FIF or FLP out of those attributed amounts. You must maintain attribution accounts if you wish to prevent double taxation under the FIF measures.