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Paris, June 1, 2006
Vivendi Resolves Tax
Dispute Over DuPont Shares
Vivendi announced today that it has
reached an agreement with the Internal Revenue Service (IRS) bringing to a close
their dispute concerning the amount of tax due on the redemption of DuPont
shares in April 1995.
The IRS, which contested the tax treatment applied
by Seagram at the time, demanded payment of $1.5 billion in tax plus interest
accumulated since 1995.
The agreement reached with the IRS provides for
Vivendi to pay a total of $686 million (including tax of $284 million and
interest of $402 million) in full settlement of the dispute.
As a result
of this settlement, Vivendi will be able to eliminate the deferred tax liability
previously established in connection with this matter, i.e. $1,847 million
recorded on the Group's balance sheet as of December 31, 2005.
In
addition, under the terms of the agreement with the IRS, the 16.4 million DuPont
shares still held by Vivendi may be sold freely, subject to regular capital
gains tax provisions. For example, if these shares were sold at a share price of
$42.15 (closing price on May 30, 2006), the pre-tax proceeds of the sale would
amount to $700 million and all capital gains on the sale would be fully covered
by the deductible portion of the settlement payment and Vivendi's US tax loss
carry forwards.
Important Disclaimer: This press release
contains 'forward-looking statements' as that term is defined in the Private
Securities Litigation Reform Act of 1995. Such forward-looking statements are
not guarantees of future performance. Actual results may differ materially from
the forward-looking statements and business strategy as a result of a number of
risks and uncertainties, many of which are outside our control, including but
not limited to the risks described in the documents Vivendi has filed with the
U.S. Securities and Exchange Commission and with the French Autorité des Marchés
Financiers. Investors and security holders may obtain a free copy of documents
filed by Vivendi with the U.S. Securities and Exchange Commission at www.sec.gov
and with the French Autorité des Marchés Financiers at www.amf-france.org or
directly from Vivendi. Vivendi does not undertake to provide, nor has any
obligation to provide, update or revise forward-looking
statements.
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