It does not discuss all aspects
of U.S. federal income taxation that may be relevant to particular holders in
light of their particular
circumstances or to holders subject to
special rules under the Code (including, but not limited to, insurance companies, tax - exempt organizations, financial institutions, broker - dealers, partners in partnerships (or entities or arrangements treated as partnerships for U.S. federal income tax purposes) that hold HP Co. common stock, pass - through entities (or investors therein), traders in securities who elect to apply a mark - to - market method
of accounting, stockholders who hold HP Co. common stock as part
of a «hedge,» «straddle,» «conversion,» «synthetic security,» «integrated investment» or «constructive sale transaction,» individuals who receive HP Co. or Hewlett Packard Enterprise common stock upon the exercise
of employee stock options or otherwise as compensation, holders who are liable for the alternative minimum tax or any holders who actually or constructively own 5 % or more
of HP Co. common stock).
In addition, it does not describe all
of the tax consequences that may be relevant in
light of a U.S. Holder's particular
circumstances, including non-U.S. tax consequences, state and local tax consequences, estate tax consequences, alternative minimum tax consequences, the potential application
of the Medicare contribution tax, and tax consequences applicable to U.S. Holders subject to
special rules, such as: