FAQs

On April 30, 2018, Pentair plc completed the separation and distribution of its Electrical business to nVent Electric plc. In connection with this separation and distribution, Pentair’s shareholders received nVent ordinary shares on a pro rata basis. Pentair and nVent are now two wholly independent, publicly traded companies.

Each Pentair shareholder received one ordinary share of nVent for every one share of Pentair held by such Pentair shareholder at the close of business on the record date, April 17, 2018.

The Pentair Form 8937 Report of Organizational Actions Affecting Basis of Securities can be found at investors.pentair.com/investor-relations.

Below are FAQs relating to the new nVent:

Important Tax Information Concerning The Distribution Of nvent Electric Plc

All holders of Pentair and nVent ordinary shares are urged to consult their own tax advisors for a complete description of the tax consequences of the separation and distribution to them. Tax matters can be complicated, and the tax consequences of the separation and distribution to any shareholder may depend on such shareholder’s individual facts and circumstances.

What are the tax consequences of the distribution?

In connection with the separation and distribution of the Electrical business and the issuance of nVent ordinary shares, Pentair has received a private letter ruling from the Internal Revenue Service on certain issues relating to the qualification of the distribution and certain related transactions as tax-free under Section 355 and related provisions of the Internal Revenue Code of 1986, as amended (the “Code”). This ruling does not address all of the requirements for tax-free treatment of the distribution and the related transactions. Pentair has also received a tax opinion from Deloitte Tax LLP, which relies on the effectiveness of the IRS ruling, substantially to the effect that, for U.S. federal income tax purposes, the distribution and certain transactions entered into in connection with the distribution will qualify for non-recognition of gain or loss to Pentair and its shareholders pursuant to Section 355 and related provisions of the Code. Assuming that the distribution satisfies the requirements necessary for non-recognition of gain or loss to Pentair’s shareholders under Section 355 and related provisions of the Code, then for U.S. federal income tax purposes:

  • No gain or loss will be recognized by, or be includible in the income of, a holder of Pentair ordinary shares solely as a result of the receipt of nVent ordinary shares in the distribution.
  • A Pentair shareholder who receives cash in lieu of fractional ordinary shares of nVent generally will recognize gain or loss measured by the difference between the amount of cash received and the tax basis of the fractional shares. The gain or loss generally will be long-term capital gain or loss if the Pentair shareholder’s holding period for its Pentair ordinary shares exceeds one year and the Pentair ordinary shares are held as a capital asset on the date of the distribution.
  • The holding period of a Pentair shareholder for the nVent ordinary shares received in the distribution, including any fractional share interest for which cash is received, will include the holding period of such shareholder’s Pentair ordinary shares, provided that the Pentair ordinary shares are held as a capital asset on the date of the distribution.