Ann: ATO Class Ruling - In-specie Distribution of Rox Shares, page-3

I assumed that the transaction would be structured in a way that your cost base for RXL shares ($0.25 per share) would be offset by an equal and offsetting decrease in the cost base of your VMC shareholding at record date. However, that is not the case and most of the contra side of the RXL asset acquisition is assessable income rather than a decrease in the VMC cost base. This is really not at all good news for shareholders as taxable income has been created out of a capital investment. This should have been clearly disclosed to shareholders as part of the transaction sales pitch.