Reynolds Holding

DECEMBER 10, 2023

As a capital allocation decision, share buybacks intersect all three of the main corporate finance activities of investing, financing, and dividends [1]. One of the deep-seated reasons for the splitting of opinion is that share buybacks transfer wealth between shareholders [2].

Dividends 45

Dividends Total Shareholder Return Corporate Finance Finance 45

Reynolds Holding

NOVEMBER 30, 2023

07 Question: In each of 2020 and 2021, a registrant provided the same list of companies as a peer group in its Compensation Discussion & Analysis (“CD&A”) under Item 402(b) but provided a different list of companies in its CD&A for 2022. The new and revised C&DIs are included below. Answer: No.

Compliance 40

Compliance Total Shareholder Return Dividends Market Capitalization 40

Reynolds Holding

MARCH 5, 2023

Moreover, if PVP disclosure was required in a Form 10 (and its accompanying “information statement”), it would not be possible to complete column (f) of the PVP table with respect to the company’s total shareholder return (TSR), since the spin-off company would not have been publicly traded for any of the years covered by the PVP table.

Equity 45

Equity Dividends Total Shareholder Return Corporate Finance 45