QUESTION 5 (20 marks) You are a senior tax consultant and received the following email from a junior tax consultant: To: Senior Tax Consultant From: Junior Tax Consultant Subject: Tax advice Dear Senior Tax Consultant, I need your input on the following matter, please. One of my clients has a family trust which holds all the shares in a car manufacturing business, Speedy (Pty) Ltd. According to my client, the trustees of the family trust wish to interpose a holding company, Sparks (Pty) Ltd, between the family trust and Speedy (Pty) Ltd. In exchange for all the issued shares of Sparks (Pty) Lid, the family trust will transfer shares in Speedy (Pty) Ltd to Sparks (Pty) Ltd. According to my knowledge, this is not an asset-for-share transaction - am I correct in stating this? PS All the parties above are residents of South Africa. I appreciate your input as always! Kind Regards, Junior Tax Consultant REQUIRED: Advise the junior tax consultant if they are correct in stating that the above transaction is not an asset-for-share transaction. Support your answer with references to the Income Tax Act. (20 marks)