Ann: Expanded Heart Protection Discovery for Zantrene, page-204

if RAC gets some hefty upfront payments they could do a return of capital to reward shareholders. Rather than sit on a truckload of cash that doesn’t have much use.

This will have two components for tax 1. Dividend component and 2. Capital component, the split generally being determined by the nature of cash accumulated (eg was it from profits or sale of IP?)

Assuming relates to sale of IP the return of capital would just be a reduction to your share cost base. This would be tax free to the extent return of capital is less than your total cost base of your shares. Might hurt some with a low entry cost.

So as suggested by @NewToItAll a potential way to reward shareholders without needing to sell. Then royalty stream can go into Spin Co and pay ongoing dividends - great idea!