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Westfield stapled4/11/2023 ![]() Finally, as eligibility for rollover relief is determined at the parcel level, it may be the case that relief is available for some but not all parcels (eg where a capital loss arises).This makes the above process of determining cost base across each security particularly challenging. Further, despite the Westfield being a stapled structure comprised of three individual securities, it is common industry practice among custodians and platforms to record the holding as one security.The construction of the appropriate cost base as between each security in the staple is no small task, particularly where tax deferred distributions have been received on the trust component (not subject to rollover relief). As a result, the cost base of the Westfield stapled security and proceeds received as part of the transaction need to be allocated appropriately between the components of the staple. Only gains relating to the WCL share are eligible for rollover relief.The key tax implications for investors (particularly institutional investors) holding Westfield securities at the time of the event are: Under the corporate action, investors exchanged their Westfield stapled securities for cash and CHESS Depository Interests (CDIs) in respect of Unibail-Rodamco (also a stapled security comprising a Dutch and French company). Each stapled security consists of one share in Westfield Corporation limited (WCL), one unit in WFD Trust (WFDT) and one unit in Westfield America Trust (WAT). The Westfield Group is a ‘triple’ stapled security listed on the Australian Securities Exchange (ASX). The ATO released its Class Ruling on 4 July 2018 and further guidance on 13 July 2018 to assist investors in their efforts to process the event. This takeover was one of the most complex corporate actions in recent history and the tax outcomes are not straight forward. This year was no different, but with one major exception being the largest takeover in Australian history between the Westfield Group and Unibail-Rodamco just prior to year end. ![]() A core element of this is reflecting on whether any major corporate actions took place in the preceding 12 months and the tax implications. With 30 June clicking over, the managed funds and superannuation industry has been busily producing year end tax reporting on behalf of investors and members.
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