I posted this on the Leo thread, probably just as much relevance here
Return of Capital can only be paid from the Company's capital.
If you look at Leo's Balance sheet it's contributed equity is only around $100m - about what they raised back in 2022.
They are planning to distribute about $206m in T1 and $267m in T2 way surpassing that $100m.
In fact they can't use all that $100m because they have a cash balance.
Dividends are paid from profits or retained profits, unfortunately with Leo having a cash Bal around $80m after raising the $100m most of that Ganfeng money being paid out to shareholders is from profits.
In any case it's the ATO that makes the ruling.
On the other hand FFX has "issued capital" of about $300m, and I'd assume no profits. It only needs to distribute ~ $36m T1 and if it still held the Leo shares June 30, about $47m for T2. It can pay that out of it's $300m capital. So as Camban says, we'd be better off if FFX received T1, then paid it to shareholders depending on your tax situation.
Can't be franked, they've paid no Aust tax.