TASK 2' What tax issues {in particular, anti-avoidance rules and their consequences] does UPL need to bear in mind about the proposed transaction? These could impact either shareholders or UPL. Think about the fact that Australian resident shareholders would have different tax consequences to most nonresident shareholders, and that only Australian (and NZ) shareholders are proposed to be eligible for the buy- back What action can you suggest that would reduce the risk of antiavoidance provisions applying to UPL's shareholders. who otherwise might be deterred from participating in the buytrack? Please prepare two to three Powerpoint slides that set out what the risks are and how you would recommend UPL can try and mitigate them. RESOURCES You should consider the Australian Taxation Ofce's database of class rulings. in addition to the relevant income tax legislation. The ATCI has issued class rulings in ZGED which cover the relevant issues (CR 202r'2 is one example which covers some of the relevant tax issues}