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The problem here is that there is no deduction for interest incurred on amounts borrowed to pay non-concessional contributions. The solution therefore is to not borrow to pay them, and to take care to only use debt free cash flow to pay non-concessional contributions. This means, if necessary, the practitioner should deliberately borrow to pay costs where the ATO accepts that interest is deductible, in order to free up cash flow to pay the non-concessional contributions.
The transfer of the future income stream on the investment of the non-concessional contributions is the economic equivalent of large concessional (ie deductible) contributions over and above the $25,000 per member per year limit ($50,000 if over age 50, until 2012).
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