Related Persons. (1) Where a person subject to the taxing jurisdiction of one of the Contracting States and any other person are related and where such related persons make arrangements or impose conditions between themselves which are different from those which would be made between independent persons, any income, deductions, credits, or allowances which would, but for those arrangements or conditions, have been taken into account in computing the income (or loss) of, or the tax payable by, one of such persons may be taken into account in computing the amount of the income subject to tax and the taxes payable by such person.
(2) Where a redetermination has been made by one Contracting State to the income of one of its residents in accordance with paragraph (1), then the other Contracting State shall, if it agrees with such redetermination and if necessary to prevent double taxation, make a corresponding adjustment to the income of a person in such other Contracting State related to such resident. In the event the other Contracting State disagrees with such redetermination, the two Contracting States shall endeavor to reach agreement in accordance with the mutual agreement procedure in paragraph (2) of Article 25 (Mutual Agreement Procedure).
(3) For purposes of this Convention, a person is related to another person if either person owns or controls directly or indirectly the other, or if any third person or persons own or control directly or indirectly both. For this purpose, the term "control" includes any kind of control, whether or not legally enforceable, and however exercised or exercisable.
Related Persons. Name and contact information (including home address; home and work telephone numbers; mobile telephone numbers); date of birth; gender.
Related Persons. Related Persons shall mean, with respect to any individual, such individual’s parents, spouse, siblings, children and grandchildren.
Related Persons. Where
(a) an enterprise of a Contracting State participates directly or indirectly in the management, control or capital of an enterprise of the other Contracting State, or
(b) the same persons participate directly or indirectly in the management, control or capital of an enterprise of a Contracting State and an enterprise of the other Contracting State, and in either case conditions are made or imposed between the two enterprises in their commercial or financial relations which differ from those which would be made between independent enterprises, then any profits which would, but for those conditions, have accrued to one of the enterprises, but, by reason of those conditions, have not so accrued, may be included in the profits of that enterprise and taxed accordingly.
Related Persons. With respect to each Limited Partner that holds Units or Interests by virtue of being a Family Trust or Family Member (or other permitted transferee or holding entity of Units or Interests hereunder) of a Related Person (including, in the case of the Founder, each Holding Partner), any reference to an employment agreement or other employment-related matter with respect to such Limited Partner (including the event of any termination of employment) shall be deemed to refer to such Limited Partner’s Related Person.
Related Persons. Except as set forth on Section 3.21(a) of the Seller Disclosure Letter, as of the date hereof, and as immediately after the Closing, none of the assets, including Intellectual Property, used in the business of either Company and its Subsidiaries is or will be owned, or leased from a third party, by ASC or any of its Affiliates (other than such Company and its Subsidiaries). Section 3.21(b) of the Seller Disclosure Letter sets forth a true and complete list of all material Contracts to which either Company or any of its Subsidiaries, on the one hand, and ASC or any of its Subsidiaries (other than either Company and its Subsidiaries), on the other hand, are party to.
Related Persons. Related Persons" shall mean any revocable --------------- or irrevocable trust or custodianship the beneficiaries of which may include only Executive, his spouse and/or his lineal descendants by blood or adoption, or a corporation, partnership or limited liability company of which Executive, his spouse and/or his lineal descendants by blood or adoption are the sole direct or indirect owners.
Related Persons. (i) except as otherwise disclosed by the Customer, none of the Customer’s spouse(s) (and the spouse’s dependents), parents, brothers, sisters, children, their spouses, directors, managers, controlling shareholders (whether directly or indirectly interested) or agents and guarantors of the Facility (where applicable) are employed by the Bank or its subsidiaries; and
(ii) except as otherwise disclosed by the Customer, none of the persons set out in paragraph (i) above are related to any director, officer or employee of the Bank or its subsidiaries currently.
Related Persons. Name and contact information of dependents or beneficiaries (including home address; home and work telephone numbers; mobile telephone numbers); date of birth; gender; emergency contacts; beneficiary information; dependent information.
Related Persons. See Section 13.1. --------------- ------------
