This is not a tax free spinoff. Since MFGP is a foreign company, rule 367(a) applies and all profits up to the spinoff must be recognized and taxed. (no losses allowed) There is a 1099-B created for the spinoff under Seattle Spinco. Here is the spinoff order HPE->Seattle Spinco->MFGP. It shows the proceeds as the value of all Seattle Spinco shares at FMV merger price.
