Clymene, re tax ruling FFX/LLL, I could not get any info from...

First 7345 Last

Share
Profile

Follow
giannid

383 Posts.

2

17/08/22

11:38

Post #: 63162773
Share

Originally posted by Clymene: ↑

The raising of capital and the ratio of shares issued in the demerger do not have any bearing on the technical issues considered by the ATO in providing a class ruling under section Division 125 -( that is it is a demerger under the ITA).

Generally the class ruling will also consider application of section 6(1), 44(4),45A,45B and 45C - is the distribution a dividend or not etc - need to see specific application but this is the general matters considered.

Under Div 125, Firefinch must retain less than 20% of LLL on demerger, in conjunction with demerger LLL must not seek to do a capital raising other than with inspecie beneficiaries (there are some minor outs here for shortfalls and other matters) otherwise it is not considered a demerger under ITA and that I imagine will cause immense grief for most FFX shareholders.

But for me what is important is that the In specie distribution is not consider a dividend (ouch - see BHP May 2022 inspecie distribution of Woodside shares).

The split of my original FFX shares cost base that gave rise to my in specie LLL. Eg if my original FFX shares cost 50cents, then a portion of this cost base will be applied to the LLL shares reducing my FFX cost base. Ensuring the tax character (revenue vs capital; account and dates of acquisition etc) pertaining to my purchase of FFX shares is retained.

These matters go directly to the value proposition of the demerger for shareholders.

From the outside it all looks pretty vanilla to me and it does not seem that either FFX or LLL have breached any of the DIV125 requirements so all should be good - fingers crossed.

Expand

Clymene, re tax ruling FFX/LLL, I could not get any info from the ATO’s website.
Were you able to?

FFX Price at posting: 20.0¢ Sentiment: Buy Disclosure: Held
Upvote

0 Great analysis

Reply

Top Stories

LRV

Larvotto identifies new exploration target at NSW's Hillgrove, boosting shares by nearly 20%

RCE

Recce's R327 found effective against E.coli during clinical trial

SS1

Sun Silver gets that drill to thrill feeling from high grade hits at Maverick Spring

SVL

Silver Mines models five new calderas close to 396Moz Bowdens deposit

Week 26 Wrap: Cerberus of inflation barks – rents, electricity & fuel – and world watches two elders bicker

AVA

Ava Risk Group expands US presence with A$0.7M Substation Deal

LU7

Lithium Universe (ASX:LU7) board visits Quebec to engage key stakeholders

Wealth Within weighs in on shock 4% inflation read – and stocks that could survive the gloom

Microcap Wrap: 5 explorers with news out today

CMX

ChemX Materials kicks off first stage works at WA high purity alumina pilot

There are more pages in this discussion • 2,651 more messages in this thread...

First 7345 Last

Add FFX (ASX) to my watchlist

(20min delay)
Last 20.0¢		Change 0.000(0.00%)		Mkt cap ! $236.5M

Open	High	Low	Value	Volume
0.0¢	0.0¢	0.0¢	$0	0

Clymene, re tax ruling FFX/LLL, I could not get any info from...

Larvotto identifies new exploration target at NSW's Hillgrove, boosting shares by nearly 20%

Recce's R327 found effective against E.coli during clinical trial

Sun Silver gets that drill to thrill feeling from high grade hits at Maverick Spring

Silver Mines models five new calderas close to 396Moz Bowdens deposit

Week 26 Wrap: Cerberus of inflation barks – rents, electricity & fuel – and world watches two elders bicker

Ava Risk Group expands US presence with A$0.7M Substation Deal

Lithium Universe (ASX:LU7) board visits Quebec to engage key stakeholders

Wealth Within weighs in on shock 4% inflation read – and stocks that could survive the gloom

Microcap Wrap: 5 explorers with news out today

ChemX Materials kicks off first stage works at WA high purity alumina pilot

Featured News

Featured News

Clymene, re tax ruling FFX/LLL, I could not get any info from...

Top Stories

Larvotto identifies new exploration target at NSW's Hillgrove, boosting shares by nearly 20%

Recce's R327 found effective against E.coli during clinical trial

Sun Silver gets that drill to thrill feeling from high grade hits at Maverick Spring

Silver Mines models five new calderas close to 396Moz Bowdens deposit

Week 26 Wrap: Cerberus of inflation barks – rents, electricity & fuel – and world watches two elders bicker

Ava Risk Group expands US presence with A$0.7M Substation Deal

Lithium Universe (ASX:LU7) board visits Quebec to engage key stakeholders

Wealth Within weighs in on shock 4% inflation read – and stocks that could survive the gloom

Microcap Wrap: 5 explorers with news out today

ChemX Materials kicks off first stage works at WA high purity alumina pilot

Featured News

Featured News