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D Co is a company that has divided its shares into two classes: Class A shares belonging to shareholders that acquired their shares before 20

D Co is a company that has divided its shares into two classes: Class A shares belonging to shareholders that acquired their shares before 20 September 1985 and Class B shares belonging to shareholders that acquired their shares on or after that date. During the current year, the company pays a franked dividend to both classes of shareholders. The Class A shareholders receive a slightly lesser dividend than Class B shareholders, but the Class A shareholders also receive a return of capital to compensate them for the lower dividend. Discuss which anti-avoidance rules may potentially apply to the Class A and Class B shareholders. Which section applies to capital benefits distributed to the Class B shareholders if the scheme is not entered into for a purpose of obtaining a tax benefit

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