Seagate 2004 Annual Report Download - page 21

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Table of Contents
On July 19, 2005, we declared a dividend of $0.08 per share to be paid on or before August 19, 2005 to our shareholders of record as of
August 5, 2005.
To the extent that the amount of any distribution exceeds our current or accumulated earnings and profits for U.S. federal income tax
purposes in any taxable year, the distribution will be treated as a return of capital for U.S. tax purposes, causing a reduction in a shareholder’s
adjusted tax basis in the common shares. Because we did not have any current or accumulated earnings and profits for U.S. federal income tax
purposes for our taxable year ended July 1, 2005, distributions on our common shares during this period were treated as a return of capital
rather than dividend income for U.S. federal income tax purposes. There can be no assurance, however, that we will not have current or
accumulated earnings and profits for U.S. federal income tax purposes in future years. To the extent that we have current or accumulated
earnings and profits for U.S. federal income tax purposes, distributions on our common shares will not be treated as a return of capital
distribution and will be treated as dividend income, taxable to U.S. shareholders. If during fiscal year 2006, we engage in activities such as the
repayment of our term loan, the repurchase of our common shares, etc., which require significant usage of cash beyond the normal quarterly
distributions to shareholders, it is likely that we would generate current earnings and profits. If this occurs, all distributions made during fiscal
year 2006 are anticipated to be treated as dividend income, even if the activities occur after the distributions are made.
Furthermore, we believe that we were a foreign personal holding company for U.S. federal income tax purposes for our taxable years
ended July 1, 2005 and July 2, 2004. Pursuant to the American Jobs Creation Act of 2004, foreign corporations will be excluded from the
application of the personal holding company rules of the Internal Revenue Code of 1986, as amended (the “Code”), effective for taxable years
of foreign corporations beginning after December 31, 2004. For the Company, the effective date is its fiscal year beginning July 2, 2005. As a
result, if taxable distributions on our common shares are made after July 1, 2005, U.S. shareholders who are individuals may be eligible for
reduced rates of taxation applicable to certain dividend income (currently a maximum rate of 15%) on distributions made after the effective
date.
19
Record Date
Paid Date
Dividend
Per Share
February 14, 2003
February 28, 2003
$
0.03
May 9, 2003
May 23, 2003
$
0.03
August 8, 2003
August 22, 2003
$
0.04
November 7, 2003
November 21, 2003
$
0.04
February 13, 2004
February 27, 2004
$
0.06
May 7, 2004
May 21, 2004
$
0.06
August 6, 2004
August 20, 2004
$
0.06
November 5, 2004
November 19, 2004
$
0.06
February 4, 2005
February 18, 2005
$
0.06
May 6, 2005
May 20, 2005
$
0.08