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 non-resident 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 anti-avoidance provisions applying to UPLs shareholders, who otherwise might be deterred from participating in the buy-back