I think from the initial post it can be inferred that Mark F was...

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    I think from the initial post it can be inferred that Mark F was talking about if their estate had to dispose of the shares (i.e. to fund his funeral or costs in administering the estate) or if the beneficiaries were to dispose of the shares shortly after inheriting them. 

    We also don't know Mark F's circumstance. If he were to have non-resudent beneficiaries then a capital gain would be realised just before his death (  http://www8.austlii.edu.au/cgi-bin/viewdoc/au/legis/cth/consol_act/itaa1997240/s104.215.html) and those gains would not be disregarded
 
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