Can someone please tell me what’s going on?, page-50

Yes the goal posts keep changing. But there seems to be a reason for the madness but not the timing of events. The tax advisors stuffed up by not updating the ruling request- its their responsibility.You would not expect any Coy Director to be on top of this sort of STUFF. Its the tax advisor to come up with a plan of ideas. Its the directors duty to keep them informed and updated.

my understanding is the CFI dividend received can't be applied against the FFX losses.

From Chat GPT
"If the dividend is CFI, then it is likely non-assessable non-exempt income (NANE) for tax purposes.Therefore, no tax is payable — and the company does not even need to apply its tax losses.
1. What Is CFI to an Australian Company?
CFI is primarily designed to allow non-resident shareholders to receive foreign-sourced income via an Australian company without Australian tax (e.g., withholding tax).However, when an Australian company receives a dividend funded from CFI, it typically treats that dividend as:Non-assessable, non-exempt (NANE) income..
2. Effect of NANE Income
It is excluded from assessable income.It does not reduce carried-forward tax losses.It does not trigger tax liability.It may not create franking credits unless rules for foreign income tax offsets (FITOs) apply. So, in this case:

Dividend received (CFI)
Assessable income$0
Tax losses used$0
Tax payable$0
Carried-forward losses remain the same
Summary:If the dividend is CFI and non-assessable under tax law:The company pays no tax.It preserves its tax losses for future use."

AND so it seems to be an unfranked dividend when its paid to FFX shareholders.

IT'S A CLUSTERF@CK