"Opes took the stock off then put it back on the client account just before the 12 month period"
What is the point of the 12 month rule then if all it takes to get around is to make some internal book entry? Shouldn't the client be involved in this process to ensure it's a valid transaction? This is another example of Opes/ANZ hiding the true nature of the arrangement by not alerting to the client to requirements/clauses under the AMSLA.
From my reading the rule is in place for tax reasons at the behest of the ATO as it plugs a lookphole in transferring assets without triggering CGT. The ATO will have a field day with this little slight of hand. They don't take any prisoners...I would look out ANZ, you could have just exposed yourself to tens of millions of dollars in Cap Gains Tax
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