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Hold-rated new Norsk Hydro (NHY) trades near roughly estimated net present value [NPV] of $13 a share, revised up from $11 after disclosure of second quarter results on July 24. Because aluminum will not be an independent company until October 1 when NHY oil operations become part of buy-rated Statoil (STO), there is no history of unlevered cash flow (Ebitda) for a valuation estimate.

At the same time, industry confidence in the light metal is exceedingly strong considering Rio Tinto (RTP)’s $40 billion bid for Canada’s Alcan Inc. (AL). Finally, taxable U.S. investors who purchased American Depositary Shares of buy-rated old NHY within the last three years may find it desirable for tax purposes to realize a loss in new NHY.

The value of 0.8622 Statoil to be received would be taxed as a qualified dividend at the maximum rate of 15%. The taxable income from the distribution might be offset, at least partially, by a possible loss on the sale of NHY as the price drops after the distribution. Investors who purchased NHY since October 1, 2006, may be able to incur a short-term loss that might have its best value in offsetting other short-term gains.

Originally published on July 24, 2007.