Page 1

July saw the new Senate take its place with 24 senators being re-elected and 12 new senators taking their place for the first time. The Greens now hold the balance of power in the Senate with 9 members in total. Nick Xenophon is the only independent remaining with Steve Fielding not receiving enough votes at the last election to retain his spot. Incidentally the last Senate seat for Victoria went to the Democratic Labour Party‘s (DLP) John Madigan, the first representative of the DLP to sit in the Senate since 1974. Of course, the main political news for the month was Julia Gillard announcing the ―Clean Energy Future‖ package outlining plans for carbon pricing. By month‘s end, draft legislation had been released for entry into parliament once it resumes in mid August. In this month‘s TechWrap we look at the compensation measures that are part of the proposed ―Clean Energy Future Package‖. We also look at draft taxation ruling TR 2011/D3 in relation to when a superannuation income stream commences and ceases as well as the release of a discussion paper for the upcoming Tax Forum.

BT Product Technical Team

The month that was...

Contents:

Draft tax ruling: when a

super income stream

commences and ceases

Details of Carbon Tax

announced

Legislative update

Tax Forum Discussion Paper

Closer economic ties with

New Zealand

Proposal paper on 50% tax

discount on interest income

Watch list

TechWrap

August 2011

Page 2

On 13 July 2011, the ATO released a draft taxation ruling TR 2011/D3 which provides the ATO view on superannuation income streams and when these commence and cease. This timing is relevant in determining whether the superannuation assets attract the tax exemption for investment earnings of assets supporting an income stream (i.e. whether the investment earnings are tax free). This draft taxation ruling has been developed in response to a query raised in 2008 with the Superannuation Technical sub-committee of the ATO National Tax Liaison Group. This query was in regard to the application of ATO ID 2004/688

1 to public offer superannuation funds.

We now outline the key views contained in this draft ruling. Detailed information and analysis of the final ruling will be provided once it is released. When an income stream commences The commencement day of a superannuation income stream ―is the first day of the period to which the first payment of the pension or annuity relates‖. In practical terms, this means:

Where the rules of the super fund provide that the income stream becomes immediately payable on a particular event, the commencement day will be the day of the event, or

In all other circumstances a member will need to apply to the trustee to receive a superannuation income stream. Therefore the commencement day cannot be prior to the member‘s application nor can it be prior to the day on which the member and trustee agree to the terms and conditions of the income stream. This ATO view may have an impact for SMSFs where the practise of ‗backdating‘ an income stream to the start of the financial year has occurred.

Also, the commencement day of the superannuation income stream cannot be before all contributions and/or rollovers which are to form the capital of the income stream have been received by the trustee. When an income stream ceases The tax exemption applying on the income stream assets will cease at the time the income stream ceases. According to the draft ruling, this will occur in the following circumstances and at the given times:

Where the trustee fails to meet the minimum pension payment requirement. If this occurs, for tax purposes the entire benefit is viewed as being in accumulation phase from the start of that financial year and any income payments made during that financial year are considered to be superannuation lump sums.

When the capital supporting the income stream is exhausted, the income stream ceases at that time.

When a full commutation of the income stream is undertaken, the income stream ceases at the time of the commutation.

On death of the member where the income stream does not automatically transfer to a dependant beneficiary as an income stream in accordance with the fund rules or binding nomination. In this case, the income stream ceases on the death of the member.

In ID 2004/688, the ATO expressed the view that where a member in receipt of a superannuation income stream dies, if there is no contingent pension liability at that time, the assets cease to be current pension assets and the tax exemption ceases on death.

Draft tax ruling: when a super income

stream commences and ceases

... Where the trustee

fails to meet the

minimum pension

payment requirement

for tax purposes the

benefit is viewed as

being in

accumulation phase

from the start of that

financial year …

Page 3

Draft tax ruling: when a super income

stream commences and ceases – cont.

Any discretion granted to the trustee in regard to the beneficiary or the form of the benefit payable (i.e. lump sum and/or pension) will not be sufficient to treat the income stream as continuing beyond the death. In these circumstances, if the trustee ultimately decides to pay a dependant beneficiary an income stream benefit from the remaining amount in the deceased‘s interest, then a new income stream commences at that time. This particular view outlined in the draft ruling is not in line with industry understanding or current practice. It is expected that this view will be challenged by industry bodies and superannuation providers in submissions on this draft ruling, which can be made until Tuesday, 26 August 2011. Date of effect When the final ruling is issued, it is proposed to apply from 1 July 2007. We envisage it will be problematic for superannuation providers to comply for past financial years, so it is hoped that the ATO‘s final ruling will provide relief for the past period where a superannuation fund‘s administrative practices were not in line with the ATO‘s view. References Draft taxation ruling TR 2011/D3 is available at: http://law.ato.gov.au/atolaw/view.htm?rank=find&criteria=AND~2011%2Fd3~basic~exact&target=EA&style=java&sdocid=DTR/TR2011D3/NAT/ATO/00001&recStart=1&PiT=99991231235958&recnum=1&tot=3&pn=ALL:::ALL ATO ID 2004/688 is available at: http://law.ato.gov.au/atolaw/view.htm?rank=find&criteria=AND~2004%2F688~basic~exact&target=JA&style=java&sdocid=AID/AID2004688/00001&recStart=1&PiT=99991231235958&recnum=1&tot=1&pn=ALL:::ALL

... Any discretion

granted to the

trustee in regard to

the beneficiary or

the form of the

benefit payable (i.e.

lump sum and/or

pension) will not be

sufficient to treat the

income stream as

continuing beyond

the death …

Example David is a member of the EFG Superannuation Fund and has been married to Aggie for 20 years. The terms of the EFG Superannuation Fund deed provide that if a member is in receipt of a superannuation income stream when the member dies the income stream will continue to be paid to their spouse, provided that person had been the member's spouse for at least 3 years prior to the member's death. David commences to receive a superannuation income stream on 1 July 2008. David dies on 1 September 2009. Aggie is automatically entitled to receive (and does receive) superannuation income stream benefits under the terms of the superannuation fund deed. There is, therefore, a continuing liability to make payments under that superannuation income stream. In these circumstances there is no cessation of the superannuation income stream.

The example below from the draft ruling illustrates the conditions which must be in place on death of the member, to ensure the income stream does not cease. These are:

the automatic transfer of the income stream to a dependant beneficiary, and

the payment of the benefit to that beneficiary in the form of an income stream.

Page 4

Transition to emissions trading scheme On Sunday, 10 July, 2011, the Federal Government released their ―Clean Energy Future‖ package with details of their carbon pricing scheme to be introduced from 1 July 2012. It is intended that for the first three years, the carbon price will be fixed like a tax before moving to an emissions trading scheme from 1 July 2015. In the fixed price stage which commences on 1 July 2012, the carbon price will start at $23 a tonne, rising at 2.5 per cent a year after inflation. From 1 July 2015, the carbon price will be set by the market. It is important to remember that the carbon pricing measures are only proposals at this stage and the ‖Clean Energy Future‖ package of measures outlined in this article are subject to the passing of legislation. In future editions of TechWrap, we will keep you informed of the passage of the ―Clean Energy Future‖ legislation through parliament Government assistance The introduction of the carbon pricing scheme will be accompanied by government assistance to social security recipients and low income earning individuals and families to help them adjust to the expected increases in the cost of living. Personal income tax cuts In an effort to help offset the impact of the carbon price, the government is proposing structural improvements to the tax system including widespread tax cuts. These changes will result in tax cuts for individuals with a taxable income of up to $80,000 in 2012/13. Further, many individuals will no longer need to lodge an income tax return from that year onward*. The proposed changes are:

raising the tax free threshold to $18,200 from 1 July 2012 and to $19,400 from 1 July 2015.

increasing the marginal tax rates of 15% and 30% to 19% and 32.5% respectively from 1 July 2012. From 1 July 2015, the 32.5% rate will increase to 33%.

changes to low income tax offset (LITO): from 1 July 2012, LITO will reduce from $1,500 to $445. However the threshold where LITO starts to taper will be increased to $37,000 and the taper rate will improve from 4% to 1.5%. From 1 July 2015, LITO will reduce to $300 and the taper rate will improve further to 1%. There will be no change to the threshold where tapering starts.

* an individual may need to lodge an income tax return for other purposes including eligibility for the Govt superannuation co-contribution.

Details of Carbon Tax announced

... the carbon

pricing measures

are proposals only

and the carbon

pricing scheme and

associated

government

assistance is

subject to the

passing of

legislation …

Did you know …

The Clean Energy Future Package contains proposals that, if passed, from 1

July 2015, will free over 1 million people from having to lodge a tax return.

Source: http://www.cleanenergyfuture.gov.au/clean-energy-future/securing-a-clean-energy-future/#content05

Page 5

2011/12 From 2012/13 From 2015/16

Income

Threshold $

Marginal

rate*

Income

Threshold $

Marginal

rate*

Income

Threshold $

Marginal

rate*

Up to 6,000 Nil Up to 18,200 Nil Up to 19,400 Nil

6,001 – 37,000

15% 18,201 – 37,000

19% 19,401 – 37,000

19%

37,001 – 80,000

30% 37,001 – 80,000

32.5% 37,001 – 80,000

33%

80,001 – 180,000

37% 80,001 – 180,000

37% 80,001 – 180,000

37%

180,001+ 45% 180,001+ 45% 180,001+ 45%

Maximum LITO of $1,500 creates an effective tax-free threshold of $16,000. LITO starts to taper from $30,000

4% taper

Maximum LITO of $445 creates an effective tax-free threshold of $20,542. LITO starts to taper from $37,000

1.5% taper

Maximum LITO of $300 creates an effective tax-free threshold of $20,979. LITO starts to taper from $37,000

1% taper

* excludes Medicare Levy

The table below summarises these tax changes and the new effective tax-free thresholds created.

Social security changes For those individuals who currently pay little or no income tax, the tax cuts proposed may not offset expected increases in the cost of living due to the carbon pricing. Consequently the government has proposed increased social security benefits and introduced targeted supplements. DVA and Centrelink pensioners and allowees Age, Service, Carer and Disability pensioners will receive a new, permanent and tax exempt Clean Energy Supplement, which will be paid in line with their regular payment cycles from 20 March 2013. This supplement equates annually to:

up to $338 for a single person, and

up to $255 for each a member of a couple. In May/June 2012 pensioners will also receive a separate Clean Energy Advance, which will be paid as an up-front and tax exempt lump sum payment of up to $250 for a single person and $190 for each member of a couple. The Clean Energy Advance is aimed at helping individuals meet additional costs for the period from 1 July 2012 to the time the Clean Energy Supplement is paid from 20 March 2013. Recipients of Newstart Allowance will receive increased entitlements of up to $218 for singles and $390 for couples (combined) on an annual basis. Individuals receiving Parenting Payment Single will receive up to $289 annually in increased benefits. These increases will be paid via a Clean Energy Advance in May/June 2012 and thereafter by a Clean Energy Supplement to be included in their Centrelink entitlements.

Details of Carbon Tax announced –

cont.

... The Clean

Energy Advance is

aimed at helping

individuals meet

additional costs for

the period from 1

July 2012 to the

time the Clean

Energy

Supplement is

paid from 20

March 2013…

Page 6

Concession/health card holders Certain card holders who experience additional increases in home energy costs as a result of medical equipment use will be eligible for the Essential Medical Equipment Payment. The Essential Medical Equipment Payment will provide assistance of $140 annually from 1 July 2012 and will be available to a person who holds, or who is caring for someone in their household who holds, one of the following concession cards:

Health Care Card;

Pensioner Concession Card;

Commonwealth Seniors Health Card; or

DVA Gold Card or White Card. To be eligible for this payment, the concession card holder must be using a prescribed medical appliance to manage their medical condition. The payment is sufficient to cover the expected change in energy costs for a kidney dialysis machine, which is the highest energy use machine covered by this payment. Commonwealth Seniors Health Card holders Holder of this card will receive assistance through the Seniors Supplement of $338 for singles, and $255 for each eligible member of a couple. They may also benefit from reduction in the proposed tax reductions. Family Tax Benefits Increases in family tax benefits (FTB) will be paid via a Clean Energy Advance in May/June 2012 and thereafter a Clean Energy Supplement will be included in the FTB payments. The increased entitlements are as follows:

FTB Part A increase of up to $110 annually, per child

FTB Part B increase of up to $69 annually, per family. Single Income Family Supplement Further assistance will be made available to middle-income families with only one primary earner as they will only benefit from one earner‘s tax reductions. These families will receive assistance through the Single Income Family Supplement of $300. Low Income Supplement Low-income households that can show they might not receive enough assistance through tax reductions or Government assistance payments to offset their expected cost increases under a carbon price will be eligible to apply for an annual, tax-exempt Low Income Supplement of $300. The following income limits will also apply:

$30,000 for singles without a dependent child;

$45,000 for couples without a dependent child;

$60,000 for singles with a dependent child;

$60,000 for couples with a dependent child. Full details of the ―Clean Energy Future‖ plan can be found at: http://www.cleanenergyfuture.gov.au/clean-energy-future/securing-a-clean-energy-future/

... Low-income

households will be

eligible to apply for

a Low Income

Supplement of

$300 where they

can show they

might not receive

enough

government

assistance …

Details of Carbon Tax announced –

cont.

Page 7

Legislative update

... three new

private health

insurance tiers to

apply from

January 2012 …

Introduced to House of Representatives 1. Fairer Private Health Insurance – Introduction of 3 Tiers

The following Bills have been introduced into parliament to start the private health insurance reforms originally announced in the May 2009 Federal Budget:

Fairer Private Health Insurance Incentives Bill 2011,

Fairer Private Health Insurance Incentives (Medicare Levy Surcharge) Bill 2011 and

Fairer Private Health Insurance Incentives (Medicare Levy Surcharge — Fringe Benefits) Bill 2011

If passed, these Bills will introduce three new health insurance tiers which aim to ensure that those with higher incomes make a larger contribution towards the cost of their private health insurance. From 1 January 2012, those with higher income for surcharge purposes will receive a reduced private health insurance rebate or be liable to pay a higher Medicare Levy Surcharge (MLS). The following table summarises the proposed changes.

2011/2012 MLS

thresholds

New MLS thresholds applying from 1 January 2012

Tier 1 Tier 2 Tier 3

Singles

$0 - $80,000 $80,001 - $93,000

$93,001 - $124,000

$124,001+

Families $0 - $160,000 $160,001 - $186,000

$186,001 - $248,000

$248,001+

Medicare levy surcharge

Nil 1.00% 1.25% 1.50%

Private health insurance rebate for premiums paid from 1 January 2012

Aged under 65

30% 20% 10% Nil

Aged 65-69 35% 25% 15% Nil

Aged 70 and over

40% 30% 20% Nil

2. Administration of early release of superannuation on compassionate

grounds Legislation has been introduced into parliament to formally transfer the administration of claims for the release of superannuation benefits on compassionate grounds from APRA to Medicare Australia. The effective date of this transfer is yet to be proclaimed. Medicare Australia has managed these claims for the last 6 months (approximately) under delegation from APRA. The delegation was initiated as this administrative function did not fit well with APRA's role as prudential regulator. Note that this is an administrative change only; there is no change to the criteria for early release of superannuation on compassionate grounds. We will keep you informed of the passage of this legislation and any resulting change in the procedures for requests to withdraw superannuation benefits on compassionate grounds.

... Medicare to

administer

compassionate

grounds payments

from super …

Page 8

3. Improving the integrity of assets test exempt income streams Currently Centrelink or DVA pensioners who have lifetime or life expectancy income streams paid from an SMSF or Small APRA Funds (SAF) are required to provide Centrelink or DVA with an actuarial certificate stating that there is a high probability that the provider of the income stream will be able to pay the income stream for its term. As an anti-avoidance measure, legislation has been introduced to parliament to clarify that SMSFs and SAFs can only provide one actuarial certificate to Centrelink or DVA for each financial year. If more than one certificate is provided for a particular financial year, only the first certificate given will have effect. If the first certificate does not meet the high probability test, the income stream will lose its asset-test exemption. The legislation also clarifies if a person does not provide a new actuarial certificate in relation to the income stream by the end of the 26 week grace period, the income stream will lose its asset-test exempt status. These measures will commence the day after this legislation receives royal assent. The Social Security and Other Legislation Amendment Bill 2011 also introduces several other measures including:

changes to give parenting payment recipients access to bereavement allowance on the death of a partner,

new Impairment Tables for assessment of disability support pensioners, and

clarification that payments made to an employee in lieu of notice of termination are redundancy payments for social security purposes

For details of these proposed measures refer to the Bill available at http://parlinfo.aph.gov.au/parlInfo/search/display/display.w3p;query%3DId%3A%22legislation%2Fbillhome%2Fr4628%22;rec=0

Consultation & Exposure Draft Legislation 1. Draft Clean Energy legislation released

The Government has released the Clean Energy Legislative Package for consultation. This package includes legislation on the income tax and GST treatment of units under the carbon pricing mechanism and legislation to give effect to the fuel tax arrangements announced as part of the Government‘s Climate Change Plan. The closing date for submissions is 22 August 2011. Further details and copies of the draft legislation is available at http://climatechange.gov.au/government/submissions/clean-energy-legislative-package.aspx

2. Draft regulations for the Shorter PDS Regime released Draft regulations which provide options for superannuation providers and simple managed investment scheme providers moving to the shorter PDS regime have been released for consultation. These regulations will allow PDS providers to:

remain in the old regime until 22 June 2012;

continue to issue supplementary PDSs until 22 June 2012; or

opt in to the new shorter PDS regime if they are ready to do so. The closing date for submissions is 12 August 2011. A copy of the draft regulations is available at http://www.treasury.gov.au/contentitem.asp?NavId=&ContentID=2112

Legislative update - cont.

... SMSFs & SAFs

can only provide

one actuarial

certificate each

year for assets

test exempt

income streams …

... Clean Energy

Legislative

Package released

for consultation …

Page 9

Consultation & Exposure Draft Legislation cont. 3. Extension for CGT loss relief for merging super funds

On 3 May 2011 the Government announced it would extend the temporary loss relief for superannuation funds that are currently in the process of merging, from 30 June 2011 to 30 September 2011. Draft legislation to implement this measure has now been released for consultation. The closing date for submissions is 22 August 2011. A copy of the draft legislation is available at http://www.treasury.gov.au/contentitem.asp?NavId=037&ContentID=2107

4. Removal of tax issues for Special Disability Trusts

The Government previously announced it would remove tax impediments faced by Special Disability Trusts (SDTs) to make them more favourable to disabled individuals and their families. Draft legislation to implement these changes has now been released for consultation. The amendments, which will apply from 1 July 2006, make SDTs more attractive by:

Providing a capital gains tax (CGT) exemption for assets transferred into an SDT for no consideration, including those distributed from a deceased estate

Extending the CGT main residence exemption to SDTs

Providing a CGT exemption for the recipient of the principal beneficiary's main residence, if the recipient‘s ownership interest ends within 2 years of the principal beneficiary's death

Ensuring equivalent taxation treatment for SDTs established under different Acts.

Submissions close on 12 August 2011. A copy of the draft legislation is available at: http://www.treasury.gov.au/contentitem.asp?NavId=037&ContentID=2089

Legislative update - cont.

... 3 month

extension of CGT

loss relief for

merging super

funds …

Tax Forum Discussion Paper

On 28 July, the government released a discussion paper in preparation for the Tax Forum to be held on 4-5 October. This forum will focus on the topics covered in the Henry tax review, formally known as Australia’s Future Tax System Review. The 35-page paper includes discussion on:

The impact on individuals of high effective marginal tax rates, including the disincentive to work, created by taper of tax offsets and withdrawal of social security benefits

The complexity of fringe benefits tax, including the different valuation rules, which create incentives for employers to structure remuneration packages to include concessionally-taxed or tax-exempt items

Proposed reforms to provide a more consistent and neutral taxation of the various types of income on savings

Changes to superannuation concessions to boost superannuation savings and allow the concessions to be more equal across low, middle and high income earners.

Provisions in the business tax system which favour certain activities and assets over others, which may interfere with investment being targeted at its most productive use.

The discussion paper can be downloaded from: http://www.futuretax.gov.au/content/Content.aspx?doc=TaxForum/Discussion_Paper.htm

... includes

discussion on the

impact on individuals

of high effective

marginal tax rates …

Page 10

In a joint media release between Deputy Prime Ministers of Australia and New Zealand, Bill English and Wayne Swan released a stock take outlining the progress made toward the creation of a Single Economic Market between the two countries. This evolved from an ‗outcomes framework‘ announced in August 2009. This stock take includes the progress made in:

converging accounting and financial reporting standards

aligning regulatory regimes, and

co-ordinating the enforcement of consumer laws. Financial advisers operating in both countries One of the aims of the Single Economic Market is to allow recognised financial advisers in Australia and New Zealand to operate across the Tasman without the need for further approvals. The stock take confirms that in New Zealand this new regulatory regime came into force on 1 July 2011, subject to certain requirements being met. We are not aware of any similar exemption allowing New Zealand advisers to operate within Australia. Portability of superannuation between both countries The progress of the portability of superannuation between Australia and New Zealand is slow and Australia is yet to release draft legislation on this issue for consultation. For more information on this joint media release, refer to: http://parlsec.treasurer.gov.au/cjp/DisplayDocs.aspx?doc=pressreleases/2011/088.htm&pageID=003&min=wms&Year=&DocType= For information on the ‗outcomes framework‘ announced in August 2009, refer to: http://www.treasury.gov.au/ttoig/content/original_outcomes_proposals.asp

Closer economic ties with New

Zealand

... One of the aims

of the Single

Economic Market

is to allow

recognised

financial advisers

in Australia and

New Zealand to

operate across the

Tasman without

the need for

further

approvals…

Did you know …

Over $1.5 million was released from superannuation in compassionate

payments in 2010/11. The average amount released was $11,316.

Source:

http://assistant.treasurer.gov.au/DisplayDocs.aspx?doc=pressreleases/2011/103.htm&pageID=003&min

=brs&Year=&DocType=0

Page 11

The Government has released a discussion paper outlining their proposed approach for the 50% tax discount on interest income as announced in the Federal Budget in May 2010. The Government has proposed this measure in recognition of tax disadvantage that individual taxpayers interest income has relative to other forms of savings income. Currently interest income is taxed at the individual‗s marginal rate, while capital gains, made on assets held longer than 12 months, receive a 50% discount. The original announcement had the measure commencing from 1 July 2011. The discussion paper, “Improving Incentives for Saving: 50% tax discount on interest income‖ proposes a delayed start date and a transition up to the full deduction proposal of $1,000. From 1 July 2012, the Government proposes to provide individuals a 50% tax discount on up to $500 of assessable interest earned from a range of savings products. This tax discount will increase to $1,000 from 1 July 2013. The savings products attracting the concessions include bonds, debentures and (the taxable component of) non-super annuity products as well as deposits held with a bank, building society or credit union. Example A: On 1 July 2012, Harry deposited $40,000 in a one-year term deposit with an effective rate of 5% per annum, earning $2,000 after one year. Harry would be required to include only $1,500 of this interest income in his tax return. Example B: On 1 July 2013, Sam deposited $40,000 in a one-year term deposit with an effective rate of 5% per annum, earning $2,000 after one year. Sam would be required to include only $1,000 of this interest income in his tax return. The Government is consulting on the details of the operation of this concession including how it would apply to interest earned indirectly by individuals, such as through a trust or managed investment scheme and also how the interest and costs incurred in deriving this interest are to be proportioned across different sources of interest income. For more detail on this measure you can view the full discussion paper at http://www.treasury.gov.au/contentitem.asp?NavId=037&ContentID=2082 Submissions close 5 August 2011.

Proposal paper on 50% tax discount

on interest income

... The original

announcement

had the measure

commencing from

1 July 2011. The

consultation paper

proposes a

delayed start date

and a transition up

to the full

deduction

proposal of

$1,000.…

Page 12

Stronger Super (the Government‘s response to the Super System review) – government‘s report in response to consultation is expected shortly. Future of Financial Advice – a public exposure of draft legislation is expected in early September. Concessional contributions cap from 1 July 2012 for individuals aged 50 and over – the government‘s response to consultation which took place earlier this year issue is expected in the coming months.

Watch list

The BT Product Technical Team

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