QDD partnership Sample Clauses

QDD partnership. The 2023 QI Agreement provides guidance on how the agreement applies to a QDD Partnership. For example, the 2023 QI Agreement provides that the QDD Tax Liability for each QDD of a QDD Partnership is the gross income components of the section 3.09 amounts, instead of the amounts of tax liability under section 881, and that it includes any withholding required to be done by the partnership with respect to its partners. It also ensures that QDD Partnerships and their partners retain the same dividend equivalent payment timing as non-partnerships, and therefore requires that a QDD Partnership determine the QDD Tax Liability of its partners and any dividend equivalent payments in the QDD’s non-equity derivative dealer capacity on the date provided in §1.871-15(j)(2) for the applicable dividend for withholding and reporting purposes. In addition, a QDD partnership must include either withholding rate pool information or specific payee information regarding its partners when it provides a withholding statement under section 6.02 of the 2023 QI Agreement and must file a recipient specific Form 1042-S for each foreign partner in connection with its withholding requirement under section 3.09 of the 2023 QI Agreement.
Sample 1
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Related to QDD partnership

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  • No Partnership, etc The Lenders and Borrower intend that the relationship between them shall be solely that of creditor and debtor. Nothing contained in this Agreement, the Notes or in any of the other Credit Facility Documents shall be deemed or construed to create a partnership, tenancy-in-common, joint tenancy, joint venture or co-ownership by or between the Lenders and Borrower or any other Person.

  • New Partners No person shall be admitted as a Partner of the Partnership except with the consent of all the Partners who shall determine the terms and conditions upon which such admission is to be effective.

  • No Joint Venture or Partnership Borrower and Lender intend that the relationship created hereunder be solely that of borrower and lender. Nothing herein is intended to create a joint venture, partnership, tenancy-in-common, or joint tenancy relationship between Borrower and Lender nor to grant Lender any interest in the Collateral other than that of secured party, mortgagee or lender.

  • No State Law Partnership The Members intend that the Company not be a partnership (including, without limitation, a limited partnership) or joint venture, and that no Member be a partner or joint venturer of any other Member, for any purposes other than federal and, if applicable, state tax purposes, and this Agreement shall not be construed to suggest otherwise. The Members intend that the Company shall be treated as a partnership for federal and, if applicable, state income tax purposes, and each Member and the Company shall file all tax returns and shall otherwise take all tax and financial reporting positions in a manner consistent with such treatment.

  • Business Partners Red Hat has entered into agreements with other organizations (“Business Partners”) to promote, market and support certain Software and Services. When Client purchases Software and Services through a Business Partner, Red Hat confirms that it is responsible for providing the Software and Services to Client under the terms of this Agreement. Red Hat is not responsible for (a) the actions of Business Partners, (b) any additional obligations Business Partners have to Client, or (c) any products or services that Business Partners supply to Client under any separate agreements between a Business Partner and Client.

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