Offshore Banking Unit: Apportioning trust management fees from portfolio investment activity

the investment must be a 'portfolio investment' (as defined by subsection 121DA(1) of the ITAA 1936); and 2. the 'portfolio investment': (a) must be managed by the fund manager in its capacity as either a broker, agent, or custodian for a non-resident; or (b) must be managed by the fund manager in its capacity as trustee for the benefit of a non-resident.