The tax treatment of Ingersoll Rand's distribution (dividends vs. return of capital) is reported to U.S. shareholders on Form 1099. This form is mailed to U.S. shareholders in January 2013 for 2012. The tax treatment of the distribution (dividends vs. return of capital) for the current year is not determined until after the end of the fiscal year. For U.S. tax purposes only, Ingersoll Rand's 2012 distribution to shareholders is classified under the U.S. Tax Code as follows:
Please also note that pursuant to U.S. Treasury Regulations, there is a completed Form 8937 in relation to this position for each distribution that took place in 2012, which you can download below.
Please also note that there is a completed Form 8937 for each distribution that took place in 2011, which you can download below as well. Ingersoll Rand’s 2011 distribution to shareholders was also classified 100% as a nontaxable return of capital.
Moreover, based on reasonable assumptions by Ingersoll Rand, all distributions to shareholders in 2013 are expected to be entirely nontaxable returns of capital (and reductions of a U.S. shareholder’s tax basis) pursuant to Section 301(c) of the U.S. Tax Code to the extent of a U.S. shareholder’s tax basis in each of its Ingersoll-Rand plc shares, with any remaining amount being taxed as capital gain, although the final determination will not be made until after the end of the fiscal year.
Pursuant to the above noted U.S. Treasury Regulations, there is a completed Form 8937 in relation to this position for the March 28, 2013 distribution, which you can download below.
You should consult your tax advisor regarding the applicable tax consequences to you in connection with any of these distributions under the laws of the United States (federal, state and local), Ireland, and any other applicable non-U.S. jurisdiction.