If you are a resident of Australia at any time during an income year and have an interest in a FIF at the end of that year or an interest in a foreign life assurance policy (FLP) during that year, you must make and keep records in Australia. This includes a foreign branch of an Australian company which has an interest in a FIF or FLP. [sections 485 and 614]
If you are an attributable taxpayer in respect of a controlled foreign company (CFC) or controlled foreign trust (CFT) that holds an interest in a FIF or FLP, you are subject to similar record keeping requirements for the CFC or CFT. [Division 11 of Part X]