MFA and AIMA Submit Joint Letter to Australian Treasury Regarding Concerns with Investment Manager Regime Legislation

On December 5, 2012, MFA and AIMA submitted a joint letter to the Australian Treasury requesting rulemaking or administrative guidance from Treasury addressing concerns about the scope of the widely held test included in the Investment Manager Regime legislation adopted in August 2012.  In our letter, we also encouraged the Australian Government to address the widely held test and a number of other concerns in future legislation, including the concentration test and the application of the rules to funds structured as partnerships and start-up funds.  We encouraged the Australian Government to address these issues to ensure that the legislation better includes foreign investment funds within the intended scope of the legislation.