I am not a tax expert although I am involved in business development within the industry, so FWIW my opinion is that it is your intention when you purchased. If I purchased CVN with the intention of holding long term, then the 50% discount will apply on profits (irrelevant for me atm since I purchased at 63.5 cents).
If events result in me selling before it returns a dividend, then that does not change anything I will still get the 50% exemption as long as held for 12 months.
If this is applied consistently, then this can open a Pandora's box because if you are geared on your investement, then does that mean you are not entitled to a deduction on the interest on the biorrowed funds to purchase the investment?
On the flip side, can you then be treated as trader and hence claim a loss for unrealised losses on your investments? Suspect that this is why the ATO may not push this line b/c most have losses on speccies rather than profits.
Would be interested in any tax experts views, but that is my understanding.
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