txn to sea tax implications

pippen raised a good question about the capital gains tax and tax loss implications of the exchange of TXN for SEA shares. I am starting this thread so we can have a focused discussion of this matter.

WARNING: I am not a tax accountant, so my interpretation below could be wrong, and therefore you should seek professional advice.

Here is the relevant ATO web page:
http://www.ato.gov.au/individuals/content.aspx?menuid=0&doc=/content/36712.htm&page=1#P17_2560

FOR CAPITAL GAINS
The TXN-SEA acquisition arrangement seems to satisfy conditions for a scrip-for-scrip rollover, so shareholder avoid paying capital gains tax until the "new" SEA shares (converted from TXN shares) are actually sold. Furthermore, use the combined time as a TXN share and a SEA share in determining the 1 year+ rule for CGT discount. (e.g. TXN shares bought on 15 March 2012 are eligible for the discounted rate if their converted SEA shares are sold AFTER 15 March 2013). Here's the relevant ATO section:

"The rollover allows you to disregard the capital gain made from the original shares, units or other interest. You are taken to have acquired the replacement shares, units or other interest for the cost base of the original interest.
You can apply the CGT discount when you dispose of new shares, providing the combined period that you owned the original shares and the new shares is at least 12 months."

FOR CAPITAL LOSSES
The ATO document states that the rollvover does not apply where there is a capital loss. Does this mean you must declare the loss in this tax year (not when you sell the converted SEA shares)? Reads that way to me, but seems odd.

HOLDING BOTH TXN AND SEA SHARES
Those of us who acquired SEA and TXN shares around the same time need to be careful about which original shares we are selling because the SEA shares likely produce a much higher cap-gain than do the SEA shares converted from TXN shares.

ADJUSTED COST BASE
The new SEA (and TPD) shares posted on our brokerage sites require us to specify the cost value. The ATO document seems to say that you use the original cost base of the TXN shares -- simple if you made only one purchase; trickier if you bought and sold a few times.

I welcome corrections to my interpretation, and again warn readers to seek professional advice on this matter.