JCI Johnson Controls International PLC

Tyco International PLC (TYC) filed a Form 8K - Other Events - with the U.S Securities and Exchange Commission on May 31, 2016.

As previously reported, Tyco International plc (the "Company"), as Audit Managing Party under each Tax Sharing Agreement dated September 25, 2007 (among the Company, TE Connectivity Ltd. and Covidien plc (which on January 26, 2015 was acquired by and now operates as a subsidiary of Medtronic plc) and dated September 28, 2012 (among the Company, The ADT Corporation and Pentair Ltd. (along with TE Connectivity and Covidien, the "Parties")), entered into Stipulations of Settled Issues with the Internal Revenue Service (the "IRS") intended to resolve all Federal tax disputes related to the previously disclosed intercompany debt issues for the Company's 1997 - 2000 audit cycle before the U.S. Tax Court. The Stipulations of Settled Issues were contingent upon the IRS Appeals Division applying the same settlement terms to all intercompany debt issues on appeal for subsequent audit cycles (2001 - 2007). On May 17, 2016 the IRS Office of Appeals issued fully-executed Forms 870-AD that effectively settle the matters on appeal on the same terms as those set forth in the Stipulations of Settled Issues, and on May 31, 2016, the U.S. Tax Court entered decisions consistent with the Stipulations of Settled Issues. As a result, all aspects of this controversy that were before the U.S. Tax Court and Appeals Division of the IRS have been finally resolved for audit cycles 1997 - 2007. During the second quarter of fiscal 2016, the Company paid $120 million to TE Connectivity Ltd. and $2 million to Covidien, representing its share of the total amount payable to the IRS in connection with this matter. The Company does not expect to recognize any additional charges related to this matter, as the Company had previously recorded sufficient reserves with respect to this controversy and its obligations under the Tax Sharing Agreements.

The full text of this SEC filing can be retrieved at: http://www.sec.gov/Archives/edgar/data/833444/000083344416000181/form8-k.htm

Any exhibits and associated documents for this SEC filing can be retrieved at: http://www.sec.gov/Archives/edgar/data/833444/000083344416000181/0000833444-16-000181-index.htm

Public companies must file a Form 8-K, or current report, with the SEC generally within four days of any event that could materially affect a company's financial position or the value of its shares.

(END) Dow Jones Newswires

May 31, 2016 16:23 ET (20:23 GMT)

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