|
June 1, 2006: Vivendi
Resolves Tax Dispute Over DuPont Shares
Download the
press release
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.
|