Originally posted by loki01
Kojack
Re your comment - "Then you have A$300m in carried losses worth up to $90m."
I am pretty sure that TRY will not pay any tax in Australia if its Guyana operations are profitable since these are taxed under their laws, and I expect that under some international tax treaty they would not also be required to pay tax on them in Australia. TRY has not had any income generating operations in Australia for over 8 years on which it could pay local taxes, except perhaps in respect of interest earned on cash balances.
The $300m+ in carried losses relate to a range of assets including the Casposo mine which would have been a significant write-off. Another major part of the write-offs I suspect would relate to the carrying value of Karouni, especially in respect of the valuation placed on the assets acquired during the merger with AZH.
Perhaps somebody with a stronger hold on accounting concepts can explain more clearly to you why there is unlikely to be any tax benefits from the carried losses, other than perhaps in relation to carried forward operating losses in respect of the Guyana mine, about which and their tax arrangements I have no knowledge.
However, I appreciate your posts on most issues so please keep them coming.
loki
The carried losses are at the corporate level in Australia. You are right, a lot depends on the details. And also that it makes little difference to the earnings from the Guyana mine. But it might be more complex than you think. E.g. Troy is paying a 8.5% royalty in Guyana. It seems that royalty counts against tax, so any taxes on earnings in Gyuana are reduced by the royalty amounts. It is extremely unlikely that Troy has to pay alot of tax in Guyana as the royalty currently is equivalent to no tax if you have AISC of US$880. Below that and they have to pay tax again. Don't know what that means for taxes in Australia, it could very well mean Troy will have to pay taxes on the margin above $880 in Australia. Also we do not know the arrangements between Troy parent and Troy Guyana. Troy Guyana will owe the parent a lot of money and so huge amounts of internal debt repayments could happen. Also there seem to be different companies holding the tenements and operating the plant. If Troy revalues Karouni it will reduce the carried losses, but then again after a mining project is finished (and everyone will finish one day) the value will drop to 0, meaning if Karouni gets revalued to a higher value Troy can write off that higher value against earnings over the years again reducing taxes. In the end $300m carried losses means you can earn up to $300m without paying taxes. Could be interesting as a corporate shell for someone with earnings in Australia. I do not know current market rates for such deals, would involve huge huge discounts probably.
I agree that currently the potential value of carried losses is a mere distraction, but it is not as if Troy has nothing besides Karouni. Similar with the royalties. 2% royalty on Sandstone, cannot be sold currently. But Alto Metals did encounter interesting results and I am sure ultimately the royalties will be worth a couple of millions, maybe dozens of millions (best case) down the road. Only if we get a genuine bull market in gold though. The 30% Casposo stake has a value and even that is forgotten again and again. Deember will be interesting because Troy will either get US$1.5m for the next 10% stake of Casposo or Austral Gold is forfeiting the 10% stake forever meaning they cannot ever get rid of Troy. As long as Troy has a stake they get proportional amounts of any dividends Casposo pays to owners. Austral gold avoided to get anything out from Casposo so far. Fertile exploration ground there too, so I think Austral will do very well in the long run.
