On March 6, 2021, we entered into a definitive agreement with a consortium led by STG, pursuant to which STG agreed to purchase our Enterprise Business for an all-cash purchase price of $4.0 billion, which closed on July 27, 2021. In connection with the divestiture of the Enterprise Business, we entered into a transition service agreement under which we will provide assistance to STG including, but not limited to, business support services and information technology services as well as a commercial services agreement under which we will provide certain product services and licensed technology.

The following table presents the aggregate amounts of the classes of assets and liabilities sold under the definitive agreement with STG:


(in millions)	June 26, 2021		December 26, 2020
Assets:
Accounts receivable, net	$	194	$	290
Deferred costs		102		96
Other current assets		21		16
Total current assets of discontinued operations		317		402
Property and equipment, net		37		34
Intangible assets, net		881		915
Goodwill		1,413		1,413
Deferred tax assets		40		43
Other long-term assets		157		155
Total assets of discontinued operations	$	2,845	$	2,962
Liabilities:
Accounts payable and other current liabilities	$	37	$	39
Accrued compensation and benefits		18		18
Accrued marketing		8		6
Lease liabilities, current portion		17		15
Deferred revenue		845		892
Total current liabilities of discontinued operations		925		970
Deferred tax liabilities		6		7
Other long-term liabilities		58		51
Deferred revenue, less current portion		545		604
Total liabilities of discontinued operations	$	1,534	$	1,632

The following table presents information regarding certain components of income from discontinued operations, net of taxes:


	Three Months Ended				Six Months Ended
(in millions)	June 26, 2021		June 27, 2020		June 26, 2021		June 27, 2020
Net revenue	$	346	$	333	$	677	$	664
Operating income	$	54	$	49	$	73	$	58
Income before income taxes	$	51	$	49	$	69	$	58
Income tax expense	$	11	$	9	$	18	$	17
Income from discontinued operations, net of taxes	$	40	$	40	$	51	$	41

The following table presents significant non-cash items and capital expenditures of discontinued operations:


	Six Months Ended
(in millions)	June 26, 2021		June 27, 2020
Depreciation and amortization	$	41	$	112
Equity-based compensation expense	$	45	$	3
Additions to property and equipment	$	3	$	4

In July 2021, two amendments to the definitive agreement with a consortium led by STG for the purchase of the Enterprise Business were executed. The amendments modified certain provisions for assets and liabilities to be transferred as well as the timing and procedures for transfer of certain assets and employees in foreign jurisdictions in connection with the sale, and clarifying requirements for maintenance of such assets prior to transfer. The amendments also include certain other modifications or clarifications of the purchase agreement.

On July 27, 2021, we completed the sale of certain assets and the assumption of certain liabilities of our Enterprise Business to STG for an all-cash purchase price of $4.0 billion. In connection with the transaction, we expect to recognize a gain in excess of $2 billion, net of taxes. As a direct result of the taxable gain on the Enterprise Business divestiture, we expect to realize certain tax benefits subject to our TRA and thus we expect to record a TRA liability of between $170 million and $260 million.

Subsequent to the completion of the sale of the Enterprise Business, we notified our lenders of our intent to prepay approximately $1 billion of our indebtedness, which will be completed in August 2021. In connection with this prepayment, we expect to incur a loss on extinguishment of debt in Q3 2021 of approximately $10 million related to recognition of unamortized discount and deferred financing costs (Note 11). We also terminated $150 million of our $250 million notional interest rate swap that had an expiration date of January 29, 2022 (Note 13).

Additionally, on August 3, 2021, the Board of Directors of McAfee Corp. declared a special one-time cash dividend of $4.50 per share of Class A common stock payable to shareholders of record at 5:00 PM Eastern Time on August 13, 2021 (the “Special Dividend”). In connection with the declaration of the Special Dividend, the Board of Directors of McAfee Corp., as sole managing member of FTW, authorized FTW to declare a special one-time cash distribution to its members in the aggregate of approximately $2.8 billion (the “Special Distribution”). The Special Distribution is expected to result in the payment of approximately $1.7 billion to Continuing LLC Owners and approximately $1.1 billion to McAfee Corp. McAfee Corp. will use approximately $0.8 billion of its share of the Special Distribution to pay the Special Dividend to participating shareholders on or about August 27, 2021. Under the provisions of our equity plans, the Special Dividend is anticipated to constitute an equity restructuring under applicable accounting rules, which will require us to make certain adjustments to our outstanding equity awards.

In connection with the sale of the Enterprise Business we have incurred costs consisting primarily of consulting fees, legal fees, and other costs to facilitate the sale transaction and the separation of the Enterprise Business, including incremental costs associated with data disentanglement and acceleration of data migration to the cloud. During the three and six months ended June 26, 2021, we recorded $39 million and $61 million, respectively, for these transition costs. These costs are recorded within Income from discontinued operations, net of taxes, on the condensed consolidated statements of operations.