• 3M will pay the earplug plaintiffs a cumulative $6.0B (consisting of $5B cash and $1B stock) over seven years (2023-2029). These payment obligations have a pre-tax net present value (NPV) of $5.3B (using a 5.6% discount rate).
• 3M expects that the settlement payments will be fully tax-deductible, so the NPV of the settlement payments on an after-tax basis is in the $4.0-4.5B range.
• 3M hopes to recover as much as $1.5B of the settlement amount from liability insurance. Any recovery from insurance will reduce the settlement NPV; in the best-case scenario, the after-tax NPV of the settlement would be approximately $3B.