AVZ Discussion 2022

[Frank]

https://x.com/anonymous_seeu/status/1912422662477107541

https://x.com/Twinkle887788/status/1912446018073030807

 

[Aeolian]

3 months deliberation
then court hands down findings
then awards (think of this as sentencing)
then appeals process (inevitable regardless of who's found to be in violation)
then liquidation of awards
If it goes the full process, we'll definitely be into 2026 (but for the record, I don't believe this will be allowed to proceed in June).

Also, (and my apologies if this sounds negative), we must remember that if all goes to plan, we'll be selling at asset level. This means it's highly likely that proceeds will get returned to SHs as non franked dividends after the exploitation of any relevant local tax breaks and an ATO class ruling (this takes another 3 months). The ROC% will be relatively small.

Unfortunately this is something that the majority of SHs won't care about given they are off shore entities). Forget share buy backs etc. The only way around it as i see it is if its a deal with a RIO whereby we take equity (highly unlikely) or a very small chance of relisting with a similar asset purchased from Manono sale funds (again highly unlikely and a ridiculous amount of red tape) - again majority of large SHs are based off shore and happy with cash.

I've just been through a very similar example with LLL / FFX (forced sale to the Chinese at asset level in Mali) and PSC (sold to Chinese at asset level in Zimb). My asshole has only just recovered after the ATO turned it into a butchers bin. (Although for PSC, I was a non resident so didn't pay any tax).

If you have enough in this (and its in your own name) and it pans out how I expect, its probably worth moving to Dubai and playing golf for 2 years in order to get the non tax residency status for Aus...

I seriously hope if there is a deal it’s not like the Leo lithium one and we don’t get the majority paid out as a unfranked dividend.

This would be a terrible result for retail Australian investors who have already been through enough pain. For those in the top tax bracket, losing 48% of any dividend in tax to the ATO would be an absolute kick in the head.

 

[Hudnut]

Having an unfranky divvy could really suck, depending on your situation.

Assuming an investor is on a highest marginal tax rate is 50% for round numbers:

Example 1 - 100% increase in value from original purchase.
- Cost base is $500K (eg. bought for 50c/share)
- Value of return is $1M. (eg. equivalent of $1/share)

Returned as capital
If $1M returned as capital (shares etc) and sold, CGT discount of 50% on $500K gain is $250K.
Tax paid is $125K and Investor keeps $875K.
Overall profit from original $500K investment is $375K.

Returned as divvy
If $1M returned as divvy, then tax is $500K, and Investor keeps $500K.
No profit on original $500K cost base, and Investor has still has a $500K unrealised capital loss from the unsold and unlisted shares.

Example 2 - 400% increase in value
Even at a cost base of $250K and returned value of $1.25M:
Return as capital would mean tax of $250K and Investor keeps $1M with a $750K profit
Return as divvy would be $625K in tax, Investor keeps $625K with a $375K profit and a $250K unrealised capital loss.

Example 3 - 50% increase in value
At a cost base of $500K and returned value of $750K:
Return as capital would mean tax of $75K and Investor keeps $675K with a $175K profit
Return as divvy would be $375K in tax, Investor keeps $375K with a $125K loss and a $500K unrealised capital loss.

Unless I'm missing something, if you are on the top marginal tax rate (again, using 50% for round numbers) not being able to use your cost base as a deduction when you get the proceeds as a dividend (which is income and not capital gain), means you need to make at least a 100% profit just to break even.

Is this correct?

 

[Hudnut]

Having an unfranky divvy could really suck, depending on your situation.

Assuming an investor is on a highest marginal tax rate is 50% for round numbers:

Example 1 - 100% increase in value from original purchase.
- Cost base is $500K (eg. bought for 50c/share)
- Value of return is $1M. (eg. equivalent of $1/share)

Returned as capital
If $1M returned as capital (shares etc) and sold, CGT discount of 50% on $500K gain is $250K.
Tax paid is $125K and Investor keeps $875K.
Overall profit from original $500K investment is $375K.

Returned as divvy
If $1M returned as divvy, then tax is $500K, and Investor keeps $500K.
No profit on original $500K cost base, and Investor has still has a $500K unrealised capital loss from the unsold and unlisted shares.

Example 2 - 400% increase in value
Even at a cost base of $250K and returned value of $1.25M:
Return as capital would mean tax of $250K and Investor keeps $1M with a $750K profit
Return as divvy would be $625K in tax, Investor keeps $625K with a $375K profit and a $250K unrealised capital loss.

Example 3 - 50% increase in value
At a cost base of $500K and returned value of $750K:
Return as capital would mean tax of $75K and Investor keeps $675K with a $175K profit
Return as divvy would be $375K in tax, Investor keeps $375K with a $125K loss and a $500K unrealised capital loss.

Unless I'm missing something, if you are on the top marginal tax rate (again, using 50% for round numbers) not being able to use your cost base as a deduction when you get the proceeds as a dividend (which is income and not capital gain), means you need to make at least a 100% profit just to break even.

Is this correct?

And if the above is correct and you had an SMSF, wouldn't you be better off selling your personally held unlisted AVZ shares to your SMSF for pennies, so the dividend would be taxed at 15% instead? This would also realise your capital loss in personal tax.

 

[Ashlee]

An interesting article

RDC : La plus grande banque suisse bloque les fonds de la famille Tshisekedi, estimés à 8 milliards de dollars, mais les experts soupçonnent qu’une partie de la fortune se trouve au Qatar et aux Émirats arabes unis

Par Jean-LUC KIENGE Dans un coup de théâtre financier qui secoue les milieux bancaires et politiques, la plus grande banque suisse, UBS, a confirmé avoir gelé des fonds appartenant à la famille Tsh…

vacradiointernational.com

 

[JNRB]

An interesting article

RDC : La plus grande banque suisse bloque les fonds de la famille Tshisekedi, estimés à 8 milliards de dollars, mais les experts soupçonnent qu’une partie de la fortune se trouve au Qatar et aux Émirats arabes unis

Par Jean-LUC KIENGE Dans un coup de théâtre financier qui secoue les milieux bancaires et politiques, la plus grande banque suisse, UBS, a confirmé avoir gelé des fonds appartenant à la famille Tsh…

vacradiointernational.com

Good opportunity for Felix to sacrifice Zijin & Cominniere at the alter to show how non-corrupt he is, and sign a framework for 'responisble' development with USA

 

[Azzler]

Having an unfranky divvy could really suck, depending on your situation.

Assuming an investor is on a highest marginal tax rate is 50% for round numbers:

Example 1 - 100% increase in value from original purchase.
- Cost base is $500K (eg. bought for 50c/share)
- Value of return is $1M. (eg. equivalent of $1/share)

Returned as capital
If $1M returned as capital (shares etc) and sold, CGT discount of 50% on $500K gain is $250K.
Tax paid is $125K and Investor keeps $875K.
Overall profit from original $500K investment is $375K.

Returned as divvy
If $1M returned as divvy, then tax is $500K, and Investor keeps $500K.
No profit on original $500K cost base, and Investor has still has a $500K unrealised capital loss from the unsold and unlisted shares.

Example 2 - 400% increase in value
Even at a cost base of $250K and returned value of $1.25M:
Return as capital would mean tax of $250K and Investor keeps $1M with a $750K profit
Return as divvy would be $625K in tax, Investor keeps $625K with a $375K profit and a $250K unrealised capital loss.

Example 3 - 50% increase in value
At a cost base of $500K and returned value of $750K:
Return as capital would mean tax of $75K and Investor keeps $675K with a $175K profit
Return as divvy would be $375K in tax, Investor keeps $375K with a $125K loss and a $500K unrealised capital loss.

Unless I'm missing something, if you are on the top marginal tax rate (again, using 50% for round numbers) not being able to use your cost base as a deduction when you get the proceeds as a dividend (which is income and not capital gain), means you need to make at least a 100% profit just to break even.

Is this correct?

You know it never occurred to me that you wouldn't get to reduce your income with your cost base for a divvy payout, after missing out on the CGT discount, that's just a real kick in the teeth.

However, I suppose going forward, you still get to use that loss to offset future gains, so you don't miss out in the long term.

 

[Retrobyte]

An interesting article

RDC : La plus grande banque suisse bloque les fonds de la famille Tshisekedi, estimés à 8 milliards de dollars, mais les experts soupçonnent qu’une partie de la fortune se trouve au Qatar et aux Émirats arabes unis

Par Jean-LUC KIENGE Dans un coup de théâtre financier qui secoue les milieux bancaires et politiques, la plus grande banque suisse, UBS, a confirmé avoir gelé des fonds appartenant à la famille Tsh…

vacradiointernational.com

Send the $8bn straight to us

 

[Azzler]

An interesting article

RDC : La plus grande banque suisse bloque les fonds de la famille Tshisekedi, estimés à 8 milliards de dollars, mais les experts soupçonnent qu’une partie de la fortune se trouve au Qatar et aux Émirats arabes unis

Par Jean-LUC KIENGE Dans un coup de théâtre financier qui secoue les milieux bancaires et politiques, la plus grande banque suisse, UBS, a confirmé avoir gelé des fonds appartenant à la famille Tsh…

vacradiointernational.com

Sickening isn't it.
The ruling class in the DRC are some of the most revolting people on earth.

 

[Randenj]

An interesting article

RDC : La plus grande banque suisse bloque les fonds de la famille Tshisekedi, estimés à 8 milliards de dollars, mais les experts soupçonnent qu’une partie de la fortune se trouve au Qatar et aux Émirats arabes unis

Par Jean-LUC KIENGE Dans un coup de théâtre financier qui secoue les milieux bancaires et politiques, la plus grande banque suisse, UBS, a confirmé avoir gelé des fonds appartenant à la famille Tsh…

vacradiointernational.com

So what do you reckon: A Congo someone has started to play 'silly buggers' (again), so an American someone who knows a Swiss someone decided to give their Swiss someone a call and suddenly the Congo someone has an $8bn reason to stop mucking everyone around again?

 

[Exo324]

No one in public office should be able to amass 8bill when their country is stricken by poverty. Sickening.

 

[oxxa23]

Having an unfranky divvy could really suck, depending on your situation.

Assuming an investor is on a highest marginal tax rate is 50% for round numbers:

Example 1 - 100% increase in value from original purchase.
- Cost base is $500K (eg. bought for 50c/share)
- Value of return is $1M. (eg. equivalent of $1/share)

Returned as capital
If $1M returned as capital (shares etc) and sold, CGT discount of 50% on $500K gain is $250K.
Tax paid is $125K and Investor keeps $875K.
Overall profit from original $500K investment is $375K.

Returned as divvy
If $1M returned as divvy, then tax is $500K, and Investor keeps $500K.
No profit on original $500K cost base, and Investor has still has a $500K unrealised capital loss from the unsold and unlisted shares.

Example 2 - 400% increase in value
Even at a cost base of $250K and returned value of $1.25M:
Return as capital would mean tax of $250K and Investor keeps $1M with a $750K profit
Return as divvy would be $625K in tax, Investor keeps $625K with a $375K profit and a $250K unrealised capital loss.

Example 3 - 50% increase in value
At a cost base of $500K and returned value of $750K:
Return as capital would mean tax of $75K and Investor keeps $675K with a $175K profit
Return as divvy would be $375K in tax, Investor keeps $375K with a $125K loss and a $500K unrealised capital loss.

Unless I'm missing something, if you are on the top marginal tax rate (again, using 50% for round numbers) not being able to use your cost base as a deduction when you get the proceeds as a dividend (which is income and not capital gain), means you need to make at least a 100% profit just to break even.

Is this correct?

Your numbers are fine, it's just that the company ordinarily would wind up or do a capital buyback to assist realising the majority of your capital loss.... yo be used against future capital gains..... the tax still sucks for sure but.

 

[tonster66]

8b on a presidents salary, makes Biden look like an amateur

 

[whales]

Send the $8bn straight to us

So what do you reckon: A Congo someone has started to play 'silly buggers' (again), so an American someone who knows a Swiss someone decided to give their Swiss someone a call and suddenly the Congo someone has an $8bn reason to stop mucking everyone around again?

Security for minerals has just taken on another level.
If he was desperate to stop M23
the incentive to avoid ICC just increased 100 fold.
What a pathetic response " smear campaign "

 

[Spikerama]

Sickening isn't it.
The ruling class in the DRC are some of the most revolting people on earth.

Interesting analogy that only the tip of the iceberg is frozen.

 

[Spikerama]

@Frank @JAG

Forty Five. Sharpen those knives.

 

[Frank]

https://x.com/brendo726/status/1912622738164133889

 

[Frank]

https://x.com/AugustCohen4/status/1912670060033839200

https://x.com/Allmetpt/status/1912672156015817092

https://x.com/anonymous_seeu/status/1912676790537204093

 

[Frank]

https://x.com/anonymous_seeu/status/1912685037319012578

 

[M.Bison]

An interesting article

RDC : La plus grande banque suisse bloque les fonds de la famille Tshisekedi, estimés à 8 milliards de dollars, mais les experts soupçonnent qu’une partie de la fortune se trouve au Qatar et aux Émirats arabes unis

Par Jean-LUC KIENGE Dans un coup de théâtre financier qui secoue les milieux bancaires et politiques, la plus grande banque suisse, UBS, a confirmé avoir gelé des fonds appartenant à la famille Tsh…

vacradiointernational.com

I really hope this is a "Hey look what I can do, stop fucking around" from the Americans.