Spin-off and Special Dividend Tax Documentation
On November 27, 2015 (the “Effective Date”), Computer Sciences Corporation (“CSC”) distributed all of the shares of common stock of CSRA, Inc. (“CSRA”), a wholly owned subsidiary of CSC, to CSC shareholders (the “Distribution”). Promptly following the Distribution, on November 30, 2015, CSC and CSRA each paid a concurrent special cash dividend of $2.25 per share and $8.25 per share, respectively, to each holder of CSC common stock that received shares of CSRA common stock as a result of the Distribution (together, the “Special Dividend”). Prior to the Distribution, CSC contributed certain assets and operations relating to CSC’s North American Public Sector segment to CSRA.
The Distribution occurred by way of a pro rata dividend to CSC shareholders of record as of November 18, 2015 (the “Record Date”). Each CSC shareholder was entitled to receive one share of CSRA common stock for every share of CSC common stock held by such shareholder at the close of business on the Record Date. CSC did not distribute any fractional shares to shareholders in the Distribution.
The documentation provided below summarizes certain U.S. federal income tax consequences of the Distribution, as well as provides additional information.
The information contained herein does not apply to you if you sold, exchanged or otherwise disposed of CSC common stock prior to the time of the Distribution and you did not receive the Distribution of CSRA shares with respect to such CSC common stock after the close of the market on November 27, 2015.
The information contained herein has been prepared by CSC for general information purposes only and does not represent an opinion of counsel or otherwise constitute tax advice. It does not purport to be complete or to describe the consequences that may apply to particular categories of shareholders. The information contained herein also assumes that you are a U.S. taxpayer that holds your CSC common stock as a capital asset (generally, property held for investment). The tax rules are very complex, and you are urged to consult your own tax advisor with respect to the U.S. federal income tax consequences of the Distribution, as well as any other U.S. federal, state, local or foreign tax laws. We also urge you to read the information statement for the Distribution, noting especially the section entitled “The Transactions—Material U.S. Federal Income Tax Consequences of the Spin-Off” for more information regarding the potential tax consequences to you of the Distribution.