Jacobs Solutions distributed shares of Amentum Holdings that Jacobs still held after its April 2024 spinoff of Amentum to J shareholders. This distribution was issued as a special stock dividend. J shareholders received 0.060835 of a share of AMTM for each J share owned.
According to the SEC filings for this transaction, the tax consequences are the same as for a simple spinoff. It is structured to be a non-taxable event for J shareholders according to the supplemental to the 8-K filing of May 20, 2025. Here is a link to the 8-K supplemental filing : https://www.sec.gov/Archives/edgar/data/52988/000005298825000032/exhibit991-supplementalinf.htm
The cost basis allocation information is calculated from the average of the opening and closing prices of AMTM and J on the distribution completion date, May 30, 2025. This method to determine fair market value of the post spinoff companies is commonly used. A link to IRS Form 8937 was not available at the time these instructions were written.
It is possible the distribution may be considered a taxable dividend in the future, if the assumptions and facts of the distribution are found to not meet the criteria for being a tax-free distribution. Currently, an IRS private ruling and a private tax advisor indicate the distribution will be tax-free to J shareholders.
NOTE:
The cost basis allocation is dependent on the prices used for both Amentum Holdings and Jacobs Solutions in the cost basis allocation calculations. In our experience brokers tend to use the prices found in the guidance companies post on their websites including IRS form 8937. If available, our instructions will use the guidance in form 8937. If your broker does not use that guidance, or form 8937 is not publicly available, the cost basis of the companies involved as recorded in your accounting records and in your broker’s records may not match. This is not cause for concern. This is just due to the inexact nature of the tax code in this regard. Partnership tax returns have specific areas to reconcile these usually small differences. ICLUBcentral tax printer software automatically fills in these adjustments in the normal operation of the software using the data imported from your accounting records and that you enter from your 1099.
The Spinoff Entry
Go to Accounting > Securities > Record spinoff of securities in myICLUB.com. If you are unfamiliar with spinoff transactions you can get help at this URL: https://www.myiclub.com/faq/article.aspx?id=54
Here is the information you need to complete the spinoff.
Save the transaction and the spinoff has been entered.
