Examples of Personal Holding Company in a sentence
The Depositary shall not incur any liability for any tax consequences that may be incurred by Holders and Beneficial Owners on account of their ownership of the ADSs, including without limitation, tax consequences resulting from the Company (or any of its subsidiaries) being treated as a "Foreign Personal Holding Company," or as a "Passive Foreign Investment Company" (in each case as defined in the U.S. Internal Revenue Code and the regulations issued thereunder) or otherwise.
The Depositary shall not incur any liability for any tax consequences that may be incurred by Holders and Beneficial Owners on account of their ownership of the American Depositary Shares, including without limitation, tax consequences resulting from the Company (or any of its subsidiaries) being treated as a "Foreign Personal Holding Company," or as a "Passive Foreign Investment Company" (in each case as defined in the U.S. Internal Revenue Code and the regulations issued thereunder) or otherwise.
Country A Trust, Private Investment Company (PIC) or Personal Holding Company formed outside of Canada or the USA is any legal arrangement or entity created for holding personal assets, formed in certain jurisdictions outside of Canada or the USA.
Notwithstanding the foregoing, in the event of termination for cause, such Option (including an Option held by a Participant’s Personal Holding Company) shall expire and terminate immediately at the time of delivery of notice of termination of employment for cause to the Participant by the Corporation or a Subsidiary and shall be of no further force or effect whatsoever as to the Common Shares in respect of which an Option has not previously been exercised.
Line 4, Personal Holding Company (PHC) tax: Report the PHC tax of 12.6%, apportioned if appropriate.
A major type of taxable Subpart F offshore income is referred to in the tax code as Foreign Personal Holding Company Income (FPHC).55 It consists of passive income such as dividends, royalties, rents and interest.56 One example of FPHC income that is taxable under Subpart F is a dividend payment made from a lower tiered to a higher tiered CFC.
TheC.F.C. rules are designed to discourage the retention of earnings at the level of theC.F.C. Instead of deferral of tax, the C.F.C. rules force a U.S. shareholder owning 10% or more of the voting stock to include in a U.S. tax return the earnings generated from Subpart F Income, typically Foreign Base Company Sales Income and Foreign Personal Holding Company Income.
If the corporation is a Personal Holding Company (PHC), the corporation must calculate its tax on Schedule D using the graduated rates in addition to the 12.6% add-on tax that is reported on Schedule E, line 4.
Clubs entitled to more than one vote shall tender those votes as a block.
Apple’s Offshore Distribution Structure AppleHolding Company (AOI)Foreign Personal Holding Company IncomeDividendsDividendsForeign Base Company Sales IncomeGoodsConsumers Offshore Distribution SubsidiariesIreland/ Singapore Apple Sales Int’lIrelandAOE Third Party MFRChina Source: Prepared by Subcommittee based on interviews with Apple employees 128 Information supplied to Subcommittee by Apple, APL-PSI-000386.129 IRC Section 954(d).130 IRC Section 954(c).