"The 50% discount from holding wgo for longer then 12 months...

"The 50% discount from holding wgo for longer then 12 months only carries across to the new stx holding if stx acieve 80% . . . "

I think the problem is that you are confusing "CGT Discount" with "CGT Event". The above statement is incorrect and should instead read something like: "A CGT Event in relation to my WGO holding can only be deferred (and thus carry across to the new STX holding) if STX achieves 80%+"

In the scenario you describe above you would remain eligible for the 50% discount even if STX do not make it to 80% and you would be able to apply that to your paper profit of $2800 at the point you receive your new STX shares. If you then sold your new STX shares at 38c the day after, you would be deemed to have a profit of zero (and thus no CGT liability) on that parcel.