MFA Submits Comments to Australian Treasury on Latest Draft IMR Legislation

The Managed Funds Association ("MFA") submitted comments to the Australian Treasury regarding the most recent draft of the Investment Manager Regime legislation ("IMR 3"). MFA noted that, while the revised draft contains some positive changes, it continues to have provisions that make the achievement of its objective to encourage foreign funds to invest in Australia unlikely. In particular, MFA expressed concerns regarding the draft's (i) limits on the amount of any individual's participation in a fund, which could exclude many funds as a result of standard performance allocations; (ii) requirement to look through certain intermediary investors; and (iii) retroactive application of certain requirements to prior tax years.

See: MFA Comment Letter.