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Non-Tech : Tyco International Limited (TYC) -- Ignore unavailable to you. Want to Upgrade?

To: Larry S. who wrote (2600)	1/24/2002 3:54:28 PM
From: GVTucker	Respond to of 3770

Larry, RE: the tax situation Go to the conference call just past the 15 minute mark. Mark Swartz discusses the tax ramifications there. He clearly states that this will be a return of capital for tax purposes. I just listened to that part of the call again to make sure. Once you have received new stock in excess of your cost basis in TYC, the remainder will be taxable gain. If you don't receive stock with a value in excess of your cost basis, you won't owe tax. I think that the electronics and security-systems company isn't a new business but is a remainder, so I don't think that this will count as a return of capital, but I really am not sure. Tyco could give you better information.