Exxon and IOC have a hearing set in Whitehorse, Yukon, for obtaining the Final Order on this deal from the Yukon Supreme Court at 10:00 am on Tuesday, September 27, 2016. They expect the hearing to last only 30 minutes. Unless there are some last minute hitches, this will likely be the "effective date" and, thus, the 'closing' for consummating this deal.
On that date, our IOC shares will be surrendered and will cease to exist; we will be issued Exxon shares in exchange; we will receive some small cash amount for any fractional Exxon shares that would result from the exchange; and we will receive Contingent Rights Payments [on Exxon books only--no actual certificates], which will then become EVRs [Escrow Verification Receipts], which will pay out upon the certification appraisal which is to happen within 9--120 days after the drilling and testing of Antelope 7, thus sometime around mid-2017.
All of the foregoing proceeds will be considered taxable capital income [short- or long-term gain or loss depending on your own IOC basis amount and holding period]; EXCEPT the CRP/EVR will have a basis holding period beginning date of September 27, 2016 and a basis value equal to fair market value of the CRPs on September 27, 2016.[This FMV is to be computed to be equal to the excess of (i) the FMV of an IOC share on September 26, 2016 and (ii) the FMV of an XOM share [or fraction] to be received under the Arrangment on September 26, 2016]. Since the FMV of the Exxon shares to be received is set at $45.00/IOC share, this basis amount would be the excess value of an IOC share on 9/26/16 which is over $45.00 on that date.