Can someone please tell me what’s going on?, page-71

1) My understanding is that FFX will not pay any tax on the CFI dividend but the shareholders will pay tax on any CFI dividends received from FFX. AND that is basically what part of the tax ruling is about. There is an argument to say it should be paid from capital account and effectively a CGT event and maybe tax free to shareholders.

2) the demerger is the transfer of the lithium project out of FFX into the new company LEO. This is when you got the free shares in LEO. FFX retained 18% of LEO (with a very low cost base) and it seems if FFX distribute those LEO shares to the FFX shareholders there maybe tax to pay by us shareholders.

3) if tranche 1 and 2 cash isn’t returned there are no Tax consequences. BUT all shareholders want the cash to be paid. Its a matter of how much tax is payable by us shareholders on the dividend.