I haven't tried to tease out how much money out of the 50 billion would be raised from accumulation funds, but I think it wouldn't be much. In accumulation remember, there is tax, both on profit and on contribution which the franking credits offset. My SMSF was fairly typical , and in accumulation, it was unusual to receive a refund. The exceptions tended to be those years with large buybacks which incorporated franking credits.
So basically, I've been talking about pension phase in this discussion and I'm pretty sure that is what the change is aimed at.
As far as your comment on CGT triggering when transferring from one fund to another, sounds completely wrong, but I don't know for certain, unless you mean CGT converting the assets to cash before transfer. A source would be helpful.
Cheers
