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).
Determine FIF status - In order for the FIF
taxation rules
to apply to individuals, the cost price of offshore investments must exceed a prescribed threshold amount defined as the total purchase price of all shares.