Can someone please tell me what’s going on?, page-56

I expect the tax ruling to assign a value to the LEO shares. There is no point distributing the LEO shares held by FFX if there is any tax payable unless the value assigned to those LEO shares is insignificant- which i doubt- i guestimate maybe 20c (30c less 33% discount for the risk factor)

distributing shares or the cash proceeds of shares appears NOT to be the same or similar.
The complicating Factors that need to be taken into account , as we have just learned are CFI, and the demerger transaction.

the capital account available to use in the distribution DOES change when there is a distribution/return of capital(ROC) -this is what we want because it may trigger a CGT event(best case scenario) rather than a unfranked Dividend (worse case).

BUT it seems the tax office will treat the CFI dividends received by FFX differently, so that when FFX pay a cash dividend a proportion will be an unfranked dividend(because its CFI).

It seems the initial demerger transaction is also being treated differently rather than a ROC

In other words its a CLUSTERF@RCK