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

To: rich evans who wrote (3320)	5/28/2002 3:36:22 PM
From: Logain Ablar	Respond to of 3770

Rich: In the US a company is similar to an individual in that it can't offset capital losses against ordinary income. It can carry it back and forward though. Not sure what the situation is with a Bermuda company on this (a downside of being Bermuda based is they probably won't obtain any income tax benefit). So don't expect too much help from Uncle Sam on obtaining a benefit from the loss. Now if they were US based and had AA as the auditor maybe they would be able to book a deferred tax benefit by showing they could sell other low cost basis assets for gains to offset this realized loss (I doubt another auditor would allow it since we are talking about what a 4 to 6 billion loss). Also the reason TYC's carrying value is higher than the origianl purchase is not just CIT income but also TYC acquired a piece of CIT a couple of years ago and rolled it into TYC Finance. This amount was over a billion.