Yes, some arbitrage is possible at the moment. Oppies were ahead of themselves but now apparently falling behind a little bit. Would've expected the oppies to settle at 0.15 below the heads price. So long as the gap is larger than the strike price then in theory the arbitrage is possible. Mind you as you correctly point out the heads SP might fall in-between conversion and selling converted head. Recent indications however are that the SP will continue its upward trend and so conversion of the oppies now should work in both holder and PAAs favour.
Are there any tax implications? Anyone?
The Final Charge , Phase I/II MND Results & FDA ODD Approval Catalyst, page-387
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