Standup,I have no interest nor intention to wax lyrical with...

Standup,

I have no interest nor intention to wax lyrical with you.

Your comment regarding tax loss transferral was incorrect and I called you on it.

Simple as that.


Stove,

Spare me your generalisations.

First thing, a co with a tax loss is not a free for all otherwise all profitable co's would be buying these up in a heartbeat. The criteria required to be met in order to utilise said tax loss is well documented and purposely quite onerous. Please get this thru your head.

Second thing, provided the criteria are in fact met the even bigger challenge is to actually make a profit, something 90% of small caps fail to do.

Given that you are clearly a font of information in this area, again, I challenge you outline facts in the specific case of Freshtel where the criteria would in fact be met in order for the company to utilise the tax loss.

Keep reading......

http://www.ato.gov.au/corporate/content.asp?doc=/content/00262223.htm&page=12&H12

- FYI, ownership has substantially changed.
- The tax losses have been accumulated over 5 years and with substantially different ownership over the term.


Definition of 'Same Business Test'

http://www.ato.gov.au/corporate/content.asp?doc=/content/00262223.htm&page=15

- Same business test would likely fail or be challenged as to it's validity by the relevant body. This business started as a retailer of VOIP, it also had a wholesale whitebox business in the UK. Further it hosted it's entire backend in-house and emplyed some 70 people in AU & UK.

As to what it does today, who really knows but the facts remain that it has sold off it's UK business, sacked all of it's employees, shut down retail and subcontracts it's back end termination.

It would not pass the Same Business Test and even if it did there is the change of ownership test that would likely reduce it's tax losses from the whole of term to part of term.

You can do all sorts of research on what the Guide To Tax Losses states and draw from it any number of meanings to suit and argue based on interpretation and apparent ambiguities.

The real acid test is in the likely prospects based on others who have walked in the shoes that you intend to hang your hat on. Anecdotely, it won't pass muster and if it does the likely 'tax benefit' will be substantially less that the total $21M.

Anyway, it sounds like a great story if you can get enough people convinced in the pipeline dream attraction of it. However, people are generally not as attracted to these type of tax schemes with complicated legal crap, keep it simple and get them to buy a few thousand sq klm of land in the middle of Oz and get a believable geo report, people understand that one!


Now, Stove, reckon you can do a bit more research and present a sound business case rather than simply attempting to insult and belittle me and show off your apparent superiority by blowing me off with your highly generalised one liners?

I will accept your apology and we can shut this down now or keep it going for the next few months, your choice.