If SMSF have a single pensioner member, then that fund will get the rebate of franking credits. However, after the magic date of 28/03/2018, the status of any newly formed SMSF with a minimum of one single pensioner member, the rebates will not be allowed. Hence, this means treating the same asset vehicle differently and dependent only on an arbitrarily designated date.
My accountant claims it will never stand up. But then this is the Labor Party headed by BS.....