- what is the continuing relevance of the capital/income distinction?
 - how do our source rules apply to the typical range of investments?
 - what has been the administrative practice of the ATO to date?
 - what is the relevance of FIN 48?
 - why do we need an investment manager regime (IMR)?
 - proposals for reform (I): introduce statutory exception to common law souce rules
 - proposals for reform (II): introduce a IMR.