Sub pennies?, page-21

This seems like a classical profit transfer scenario. Maybe a tax accountant can chime in here.

Based on my understanding, which may not be correct/current, it would go something like this.
Say US Tax rate is 21%. May differ between states with some additional taxes levied or tax discounts offered for early start ups.
Aus Tax rate is 30%. Again, I'm sure there are a number of nuances around this for early start ups.

FBR will pay tax on their share of US Operating Profit at 21%.
FBR then converts after tax USD to AUD. BTW, this conversion works in our favor, more AUD for each USD. Currency translation gain.
FBR charged 9% tax (30% less 21% already taxed by US authorities) on after US tax AUD converted profits (avoids double taxation).
This keeps FBRs effective tax rate at 30% and avoids double taxation.

Now, FBR have built up a sizeable Tax Asset on their Balance Sheet from the accumulation of past losses.
I'm not sure if this Tax Asset can be offset against foreign earned income but regardless, FBR are bound to roll out WAAS within Australia at some point in the future, which will ultimately use up the Tax Asset. It's just a matter of timing if this is the case.

I'm pretty sure this is how it will go down but I am not a tax accountant. I just seem to remember this was the way things worked through the CFA Level 1/2. Maybe a Tax accountants can break this down for us in more detail. Either way, not too concerned, earning profit and having to tax on those profits is for sure a first world problem.

As usual folks, this is not investment advice. I could be wrong. Do your own research, etc etc.