BlueSkye Pty Ltd (BS) was incorporated on 12 August 1990 by its two shareholders, Basil and Joan Skye. Basil and Joan still own the two $1 shares in BS, and they have no intention of selling their shares. Basil and Joan are the only two directors, but they also rely on advice from Brenda (see below) quite a lot. On 23 September 2019, BS made its annual dividend distribution to Basil and Joan. Each shareholder received $50,000.

Advise BS on the income tax implications of the above. Fully explain your advice by reference to Australian tax legislation, tax cases and tax principles