Foreign resident CGT withholding and death

The new foreign resident withholding rules which apply to certain transactions involving the acquisition of interests in Australian real property etc do not appear to deal with the transfer of assets as a result of the death of an individual. As the rules are drafted, it appears that a withholding obligation might be triggered when an individual dies holding Australian real property valued at $2m or more and the property passes to their estate / beneficiaries / other joint tenants. As the vendor is deemed to be a non-resident under these rules unless they have obtained a clearance certificate from the ATO it appears that a liability could be triggered for the estate and/or beneficiaries, with a minimum penalty of $200k being applied. It would be very difficult in practice to deal with this situation through the existing clearance certificate or PAYG variation methods. Perhaps a specific exception needs to be considered.