Great couple of posts Powerage - very informative thank you.
Just thinking about the dividend distribution; wouldn’t a more beneficial way of distributing capital be a Return of Capital? That way, shareholders could access a capital gains tax deduction, providing the ATO okay it. I’m sure Nigel has millions of reasons to find the most advantageous return of capital mechanism possible.
Hi Shire, as I mentioned the ROC% will be a relatively small component, especially if we manage to realise anywhere near full (or even half) value on the sale of the asset.
The ROC component is returned to SHs tax free, essentially you are distributing sunk costs to SHs, easy. The rest of the capital has been derived from the sale of asset (over and above the money you invested to buy and improve the asset). I'm tipping that the ROC component will be less than 5% of the total return to SHs.
So just as an example and theres a couple of big IFs (and completely hypothetical) - but IF we split the north in exchange for compo payment (say USD$500mill) and IF we realise a sale of the south (with all things considered for USD$3.5bill) we'd end up with USD$4bill = AUD$6bill
If our sunk costs were AUD$300mill (assuming 3.5bill SOI) the dist would look something like this:
5,700,000,000 unfranked divvy (unfranked as we've paid no tax in Australia to frank against)
300,000,000 ROC (untaxed)
Or
AUD$1.62 ps unfranked divvy (taxed at your marginal rate as income if held in personal name)
AUD$0.086cps ROC (untaxed)
Now, please don't shoot the messenger with the valuation assumptions, its purely hypothetical (add a zero to each line item for all i care). I want 12 bucks a share as much as anyone...
The only caveat on the above would be the taxation treatment of any awards for compensation - I'm not experienced with this scenario, but I would imagine that once its distributed, it would be taxed as income.
FYI, In the LLL example, they are returning the proceeds of the forced sale to Ganfeng in 2 tranches after paying local CGT and other liabilities. The first tranche was distributed exactly as above (different numbers tho). The company may propose an acquisition to SHs with the second tranche - they claim to have been in DD with several listed entities (i.e. PMT or WR1 as examples). If this was voted on favourably by SHs then an aquisition of the relevant company would take place and eventually the new co would re-list with the acquired company as its main asset / on going concern - SHs could then sell on market triggering a CGT event rather than receive an unfranked divvy that effectively counts as personal income. This takes a long time - think additional 12 months all up...
Hope this clarifies, and please seek your own advice as I'm on my 4th red....
Cheers!