Fair question Yort. I thought the brief explanation provided was fairly simple and clear, though not exhaustive.
Recoupment of prior year losses are governed by s80 of ITAA (1936). It basically demands an entity must pass either the continuity of ownership test or the same business test (strictly applied).
With the change in capital structure ALF clearly fails the first limb of the test. I am uncertain as to why the Board considers it fails the same business test as we are not privy to the internal transactions which could lead that failure.
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Fair question Yort. I thought the brief explanation provided was...
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