FWIW the company is US domiciled and thus subject to US State and Federal taxes not Australian taxes. I would suggest one forgets our 30% corporate tax rate in this case. Howe the US treat accumulated losses may also be quite different from us, I don't know the answer to that question.
If ever dividends were paid (fairly unlikely within 5 years) they would be unfranked.
The Deal, page-27
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