This is how I understand it works ... please correct me if I am...

This is how I understand it works ... please correct me if I am wrong.

Newco will no doubt pay Aust Income Tax at Aust Corporate rates on profits attributed in accounts to Australian based operations and have possible franking credits.

Profits will then be transferred to to US parent and US tax paid on Total Consolidated Profits, but US Tax Office will give credits for any foreign tax already paid, so no double taxation.

Newco will distribute (part of) profits after tax to shareholders and US witholding tax (15%) will be deducted and go into US tax coffers.

Australian shareholders will declare the net dividend received + US withholding tax in their taxable income.
ATO will give a Foreign Tax Paid Offset equal to US with-holding tax paid towards any Aust Tax liability.
The offset is NON refundable, so if it is more than any tax payable ... the excess amount is lost (eg if you have a low taxable income and incur little or no tax).
So there is NO double taxation of anything.
However, I think tthe franking credits just ‘disappear’ (effectively into coffers of ATO) in this situation, unlike the situation if Newco was Aust domiciled in which case the franking credits would be distributed along with dividends to Aust & NZ shareholders to whom they are a 100% REFUNDABLE, tax credit.
Of course, Aust franking credits have zero value to other (ie non Aus or NZ) shareholders.

So, net effect appears to me to be that low paying or zero taxpaying shareholders such as smsf in pension mode will be worse off as there will be no franking credits.
To what extent future dividends would have been franked if AKE carried on as an Aust company, who knows, but as much of income would have been derived offshore, it probably be far,far less than 100%