opes alleged statement, page-67

YES I agree that might work. But what are the cgt implications for him from the disposal esp if the ATO deems his disposal to have occurred at the point he signed the stock over when the share price may have been higher.?? I dont know when he became a client nor do I know his average entry price.
I think full restitution is the only way to resolve this in a tax effective manner. All clients who signed on in the last 18 months have potentially very big cgt problems that make a cents in the dollar deal very unattractive. It is going to be difficult to get a ruling on this from the ATO prior to having to vote.

Also you are assuming that share prices will not rise before being paid. No matter how quickly the decision is made you may not have the money in your account for some months.