- 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.