ATO ID – can former step children be dependants for death benefits

The ATO have recently released an interpretative decision (ATO ID 2011/77) dealing with the issue of “former” step children, and the meaning of child and dependants for the purpose of paying out SMSF death benefits.

The Question

Consider the following example:

Jack and Jill were married. Little Bill is Jill’s son from a former marriage.

Hence Little Bill was Jack’s step son.

However, Jack and Jill’s marriage ended a few years ago in divorce.

Now, Jack has died, and did not formally adopt Little Bill under any state or territory law.

So the question is – can Little Bill be classed as a dependant of Jack’s (under the SIS Act, and hence be eligible for a death benefits payout from Jack’s super fund) because Little Bill has previously been a ‘stepchild’ of Jack’s ?

The Decision

No. A person ceases to be a ‘stepchild’ for the purposes of being a ‘dependant’ of the member under regulation 6.22 of the SISR, when the legal marriage of their natural parent to the member ends.” – ATO

So no, Little Bill will not be classed as a dependant of Jack’s in our example.

Exceptions

Note that there are a couple of exceptions in this case:

  1. Little Bill may still be a ‘dependant’ of Jack’s if for some reason Little Bill had an ‘interdependency relationship’ with Jack, or;
  2. Little Bill was a ‘dependant’ of Jack’s within the ordinary meaning (financially dependent on Jack), at the date of Jack’s death.
  3. Jack had legally adopted Little Bill.

Note also that subregulation 6.22(3) of the SISR allows death benefits to be paid to non-dependants if, after making reasonable enquiries, the fund trustee is not able to find either a legal personal representative or a dependant of the member.

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