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Attribution Managed Investment Trust Regime
Attribution Managed Investment Trust Regime

Understanding AMIT.

Reece Frazier avatar
Written by Reece Frazier
Updated over a week ago

An Attribution Managed Investment Trust (AMIT), in broad terms, is a managed investment trust (MIT) whose unitholders have clearly defined interests in relation to the income and capital of the trust and the trustee or responsible entity of the MIT has made an irrevocable election to apply the regime.

Quay Fund Services Limited (ABN 84 616 465 671 AFSL 494 886), the responsible entity, intends to make the election for the fund to operate as an AMIT.

The AMIT rules contain several provisions that will impact the taxation treatment of the fund.

The key features include:

  • An attribution model for determining member tax liabilities, which also allows amounts to retain their tax character as they flow through the trust to its members;

  • The ability to carry forward understatements and overstatements of taxable income instead of re-issuing investor statements;

  • Deemed fixed trust treatment under the income tax law;

  • Upwards cost base adjustments to units to address double taxation; and

  • Legislative certainty about the treatment of tax-deferred distributions.

Reforms to the taxation of trusts are generally ongoing. Investors should seek their own advice and monitor the progress of announcements and proposed legislative changes on the potential impact.

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