My only comment is regarding the approach. I take that your query / comments are regarding the separation of assets held in a pension phase verses an accumulation phase. You have to satisfy the ATO that those assets have been so identified. In its simplest form, that means identifying them through the minutes of the fund. A more definite, though bothersome route may be placing them into a different ebroker account. In any case, a pension phase bank account must be opened to demonstrate separation of funds. The trick is identifying which assets go into which category and that's where your observations come in. Not an issue if you have $3.2M or less for a couple (@ $1.6M max each), as you'd simply tip everything into the pension phase (and that involves a simple declaration at tax time - though timing is something you may need to discuss with your accountant). More than that total and, as you say, you need to consider tax effectiveness to dictate which "phase" the assets should sit in.
Keep in mind, also, that a couple can earn $36,402 tax free outside of super. That's another $700k-odd in investments, assuming a 5% return (ignoring franking, tax deductions, etc), but I think I'm teaching you to suck eggs here!
