What this ruling covers

The Australian Taxation Office has issued class ruling CR 2026/67, which sets out the tax treatment for shareholders of Australian Strategic Materials Limited (ASM) whose shares were acquired by a subsidiary of Energy Fuels Inc. (EFI) on 28 August 2026.

What shareholders received

Under the acquisition, each ASM share was exchanged for:

Partial scrip for scrip roll-over

Because part of the consideration was shares rather than cash only, the ruling explains that eligible shareholders may be able to choose a partial scrip for scrip roll-over. This roll-over defers the capital gains tax liability on the share or CDI portion of the proceeds received.

The $0.13 cash component per ASM share is treated as ineligible proceeds. The ruling states that tax on the cash portion cannot be deferred, regardless of whether the roll-over is chosen.

Which shareholders the ruling applies to

The ruling applies to shareholders who:

Foreign resident shareholders

The ruling states that foreign resident shareholders generally cannot access the roll-over unless the EFI shares or CDIs they received were taxable Australian property.

Key actions

This is a plain-English summary for information only, not legal or compliance advice. Always check the official source or consult a qualified professional.