W8-BEN - US tax on SMSF in Pension Phase?

Has anyone know how the change from Australian control to US is going to affect the way that dividends ..
...(if we get any)... will be taxed.. particularly in a SMSF in pension mode?
To me it looks like the US tax will be 15%.
Aust tax still zero..unless there is a capital gain and you are fortunate enough to have >3+ M