Can someone shed any light or comment on Aust Tax implications...

Can someone shed any light or comment on Aust Tax implications after the metger, esp when held by a SMSF (mainly in pension mode, so having little income tax payable liability)

1. what is likelihood of dividends being paid in longer term ...
2. Would any dividends come with partly franked due to NewCo earnings and Aust Tax paid on Aust based operations)?
3. No doubt US with-holding tax would be deducted from dividends, and Aust taxpayer will get an ATO rebate for that, but these are non-refundable rebates, so if they exceed tax payable, the excess is worthless unlike refundable Aust Tax franking credits.

So my gut feeling is, that Aust non tax payers are likely to be in a ‘worse off’ situation if/when dividends are paid than if AKE had continued as Aust ASX listed company.

Are we Aust shareholders ‘giving up benefits’ by Newco being NYSE listed and Aust holders getting CDI?
Would any other listing structure be feasible to keep benefits for Aust holders.lots of questions, but just shows my lack of understandiing/experience when it comes to having offshore domiciled investments.