What is the U.S. federal income tax treatment of any distributions made by Tyco International?
The U.S. federal income tax treatment of any distribution made by Tyco International depends on the application of U.S. federal income tax law. Although a determination cannot be made in advance, it is anticipated that distributions made by Tyco International to U.S. shareholders will generally constitute “dividends” for U.S. federal income tax purposes (notwithstanding their treatment as ordinary dividends or as reductions in registered share capital for Swiss purposes), and that they will be reported as such to the company’s shareholders and to the IRS, in accordance with, and as required by, U.S. federal income tax laws. Tyco International is a “qualified foreign corporation” for U.S. federal income tax purposes. Therefore, its dividends generally are eligible for “qualified dividend” treatment. Whether dividends paid by Tyco International in fact will constitute “qualified dividends” to any shareholder will depend on that shareholder’s specific circumstances, including the sharehol
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