Effective August 30, 2013, Murphy Oil Corporation completed the spin-off of its wholly owned subsidiary, Murphy USA Inc., into an independent, publicly traded corporation to holders of Murphy Oil Corporation common stock as of the August 21, 2013 record date.
If you are a significant distributee (who immediately before the distribution owned 5% or more MUR common stock or owned MUR securities with an aggregate tax basis of $1 million or more) who received MUSA common stock in the distribution, you are required to include a statement in your U.S. federal tax return for the year of distribution. A sample statement can be found by clicking here.
Notification to Canadian-resident shareholders
If a Canadian-resident shareholder of the share(s) of a foreign company receives a distribution of shares ("spin-off shares") from the company as a result of an eligible corporate reorganization ("spin-off"), section 86.1 of the federal Canadian Income Tax Act (the "Act") may permit such a distribution of spin-off shares to pass on a rollover basis (i.e., taxation of any gains is deferred) to the shareholder, provided the shareholder complies with certain filing requirements specified in section 86.1 of the Act.
On September 13, 2013 Murphy Oil Corporation filed the necessary information with the Canada Revenue Agency ("CRA") to review the eligibility of the Murphy USA Inc. spin-off. That review has been completed and confirmation of the eligibility can be accessed on the CRA website by clicking here.
If you are a Canadian-resident shareholder and you are considering the section 86.1 election for your 2013 tax return, you should consult your tax advisor as to the tax consequences of the distribution of spin-off shares to you and the election statement required in your tax filing.