Aussie Drink Sales Pty Ltd has an exclusive licence to distribute Monster Bull Inc soft drink products in Australia. Aussie Drink Sales Pty Ltd has four different divisions that distribute different types of products. The right to distribute Monster Bull Inc soft drinks produces 85% of the revenue of Aussie Drink Sales Pty Ltd's soft drink distribution division but only 10% of Aussie Drink Sales Pty Ltd's overall revenue.

In February 2022, Monster Bull Inc is dissatisfied with the way in which Aussie Drink Sales Pty Ltd has been distributing its products in Australia and cancels the licence. As a result of the cancellation, Aussie Drink Sales Pty Ltd decides to close down its soft drink distribution division. Monster Bull Inc pays an amount of $1,250,000 to the administration division of Aussie Drink Sales Pty Ltd as compensation for closing down its soft drink distribution division.

The most likely characterization of the $1,250,000 compensation payment to Aussie Drink Sales Pty Ltd would be:

a.

The amount would be a capital receipt to Aussie Drink Sales Pty Ltd as there was no privity of contract between the administration division of Aussie Drink Sales Pty Ltd and Monster Bull Inc.

b.

The amount would be a capital receipt to Aussie Drink Sales Pty Ltd as compensation for loss of a structural asset because Aussie Drink Sales Pty Ltd had to close down its soft drinks distribution division.

c.

The amount would be ordinary income to the soft drinks distribution division of Aussie Drink Sales Pty Ltd because there was a constructive receipt by that division.

d.

The amount would be ordinary income as compensation for loss of a revenue asset as the licence to distribute Monster Bull Inc products did not have structural significance having regard to Aussie Drink Sales Pty Ltd's overall business.

e.

None of the above.