Appreciate your response.
    I understand law do somehow permit or say do not elobrate for the fund to not hold assets under any entity name, though it may not be corporate trustee of the fund.

    If entity is not corporate trustee, no loan was in existence, how it can be inferred that it belongs to a suepr fund, hence protected from personal liability claim ?

    I wonder if ATO expects ACR lodgement in this senario because S67A structure do not exists which allows property to be held under custodian trustee.

    My understanding is ATO is currently preparing guidelines for Reg. 4.09A Separation of Assets.


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