One option to avoid the Dividend Tax vs Capital Gains Reduced...

One option to avoid the Dividend Tax vs Capital Gains Reduced tax, might be for RAC to use any funds to do a Partial Share Buyback as a % of each person's holdings.

So if they say "We just received $1B, so Trading Halt, and we will buy back 25% of each Holders shares at $15/share"
This would then buy back 50 million shares for a cost of $750m

This would then
1) Increase the shareprice which would benefit all holders long term.
2) Allow those who have held for longer than 12 months recognize Capital Gains on the shares sold, whilst still keeping the Capital Gains benefit on remaining shares.
3) For those that have done multiple purchases over time, they can talk with their accountant to see if they want to do FIFO or FILO or whatever is best suited to their position.

I am not sure if that has ever been done before with shares... and I am Not an Accountant, Lawyer or Financial Advisor... but I could see the personal benefit of something like that.