Tax inside the fund
In accumulation phase, an SMSF pays 15% on net earnings, with capital gains on assets held longer than twelve months effectively taxed at 10% after the one-third discount. In pension phase, income supporting a retirement-phase pension is generally exempt.
The gap between 10% and 45% marginal rates is why so many long-term holders consider the SMSF wrapper in the first place. The trade-off is preservation: the money is locked until a condition of release is met.
Super does not pass under the will
This is the single most misunderstood point. Superannuation is not an estate asset. It is paid at the trustee's discretion, or as directed by a binding death benefit nomination, to dependants or to the legal personal representative.
A will that leaves 'my Bitcoin to my daughter' has no effect on Bitcoin held inside the SMSF. If the fund's death benefit nomination points elsewhere - or has lapsed - the outcome can be the opposite of what the member intended.
Binding death benefit nominations
A valid binding nomination removes trustee discretion and directs the benefit. Non-lapsing nominations avoid the classic failure of a three-year nomination that expired unnoticed. Review it whenever family circumstances change.
Consider also who will be the surviving trustee. A single-member fund whose only director dies leaves nobody able to act until the legal personal representative is appointed - and if the Bitcoin is self-custodied by that member alone, the practical problem is far worse than the legal one.
Paying the benefit: cash or in specie
A death benefit can be paid as a lump sum in cash, which requires the fund to sell the Bitcoin and realise a gain inside the fund, or transferred in specie to the beneficiary as an in-specie lump sum, which is generally still a CGT event for the fund but avoids forced market timing.
There is also the taxable-component question: benefits paid to non-dependants for tax purposes are taxed, and the amount depends on the fund's component split. This needs modelling before death, not after.
The trustee's succession checklist
Confirm a valid, current binding nomination. Confirm at least two people can operate the fund and access the custody structure. Confirm the auditor has evidence linking wallets to the fund. Confirm the accountant has cost-base records. Confirm the custody structure has been rehearsed with the person who will actually have to use it.