An excellent post but if I could just add one further detail.
When you say that imputation credits are not available to non-residents of Australia:
1. it is true that non-residents will not get the benefit of the imputation credits on their domestic tax returns; BUT
2. imputation credits affect the amount of non-resident withholding tax (NRWT) which is deducted from the dividend before being paid to the overseas shareholder.
If the dividend is fully imputed then no NRWT is deducted and the full amount of the dividend will be paid to the overseas shareholder.
If zero imputation credits are attached then NRWT will be deducted at a rate which depends on the whether there is a double tax treaty between Australia and the shareholder's country of tax residence. In my case, NRWT on unimputed dividends is 30%.
So for non-resident shareholders imputation credits matter a lot.
An excellent post but if I could just add one further...
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