Australia is not unique in attempting to confront the problem of income divergence to foreign entities and must therefore address the issue of defining foreign entities that are subject to its tax laws. This article examines how tax administrators and practitioners may come to terms with one such entity, the Anstalt, Liechtenstein's most popular entity and a concept not readily intelligible to persons familiar with common law. More particularly, the author examines the emergence of the Anstaltas a tax planning device in Australia and then seeks to establish whether the Anstalt can be characterized so as to attract the provisions of Australia's income 'attribution'/'accruals' regimes or 'normal' taxing provisions which contain different models of taxation for different forms of entity organization.