I'm not too familiar with the details, but SIAF took an equity stake in TRW which now has appreciated in value (fair value of $3.41) to which I believe SIAF has booked already.
SIAF can't give us a TRW-share-dividend - that SIAF have booked a gain of - without paying taxes of that gain. From my understanding this is what they have been struggling with the past 1-1.5 years.
I'm not sure whether this applies to all 36.6%, the initial 23.89% or the latter 12.71%, but I guess RD will fill you in on it if need be
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