If they do set up a market between TRW-shareholders then you should be able to use that as the value of the TRW-shares (I expect that one to be lower than $3.4, at least till we close in on the actual listing)
You could also try to argue that the value of the TRW-shares must be lower than $3.4 if SIAF is trading below $1 pre-distribution, but not sure if the tax office will listen to that argument.
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