Yes, both the cash and stock portions of the merger consideration are taxable for U.S. federal tax purposes. To the extent that you surrendered IGT shares with a built-in gain in the merger, all of that gain will be taxable. However, to the extent that you surrendered IGT shares with a built-in loss in the merger, only approximately 35.6899% of that loss may be recognized, with the remaining approximately 64.3101% of that loss preserved in the U.S. tax basis of any IGT PLC shares you received in the merger. You should consult with your tax advisor to accurately determine the amount of gain and loss, if any, that you will recognize as a result of the merger, as well as your U.S. tax basis in any IGT PLC shares that you received in the merger.
You will receive IRS Form 1099-B early in 2016, which will be furnished by Computershare, the transfer agent.
For reference purposes, an IRS Form 8937 and supporting information explaining the U.S. tax basis of the IGT PLC shares you received in the transaction can found at:
IGT- 2015 Form 8937 – Revised May 20, 2015
IGT -2015 Form 8937 Part II statements 14, 15, 16 – Revised July 17, 2015