Ann: Change in substantial holding from MIN, page-82

As always Alexei total respect to you for all you have done and all you are doing to help us all.

If / when MIN does not get 80% am i correct in saying that NWE guys who handed over their shares for the 1:1300 deal will pay GST at that conversion stage and then again when they sell the new MIN shares?

Trying to work out what MIN will do to soften the blow to their pals who sold out, if they do anything at all!!.
Thanks in advance to whoever can jump in with their take on GST.