Tax risk. 21.1 Income or profit from any investments made by the Customer may be subject to withholding tax, capital gains tax or other taxes imposed by the country in which the investment was made or issued. Taxation may lead to a reduction in principal amounts and/or profit.
Tax risk. There can be different taxes related to cryptocurrencies in jurisdiction(s) of your citizenship and/or residence. The Company is not responsible for any of your tax issues.
Tax risk. Azteca acknowledges that the LLC is a "pass through" -------- entity and as such, Azteca will be directly taxed on Azteca's allocable share of the LLC's profits regardless of whether distributions are made to Azteca.
Tax risk. TAG MEX acknowledges that the LLC is a "pass through" -------- entity and as such, TAG MEX will be directly taxed on TAG MEX's allocable share of the LLC's profits regardless of whether distributions are made to TAG MEX.
Tax risk. Tax risk is the financial risk arising from possible misinterpretations or changes in the federal or state tax laws. To minimize this risk, NJR’s tax department monitors federal and state tax laws affecting NJNG’s business operations. In addition, Management is required to notify NJR’s tax department prior to conducting business in a new tax jurisdiction (i.e., country, federal, state or city).
Tax risk. 16.1 Income or profit from any investments made by the Customer may be subject to withholding tax, capital gains tax or other taxes imposed by the country in which the NID/INI was made or issued. Taxation may lead to a reduction in principal amounts and/or profit. SCHEDULE 3 - UNIT TRUST
Tax risk. All UK residents are subject to the UK taxation regime. All offshore funds are subject to their local tax regimes and returns to UK residents are subject to the UK taxation regime. As a result of using our Service, your tax position may change. Levels of tax, tax rules and tax relief are subject to change. You have sole responsibility for the management of your legal and tax affairs and if you are unclear as to what your position is, you should seek professional advice.
Tax risk. Changes in legislation regarding company taxation, VAT, as well as other government charges and contributions, may affect the conditions for the Group’s business activities. There is a risk that these charges and contributions will not remain unchanged in the future. The Swedish Tax Agency’s (Sw. Skatteverket) and the courts’ views on how legislation and case law in several tax areas shall be interpreted have changed during the last few years. Such changes may have a negative effect on the Group’s operations, financial position and result. There is a risk that tax rates will change in the future, or that there are other changes to the governmental system that will have an impact on the business. Any change in the tax legislation or practice that entails changes to corporate tax rate, deductibility of interest, changed possibilities for tax depreciations or limitations on tax-exempt disposals of shares in companies holding real estate may lead to a changed tax situation in the future for the Group and may have a negative effect on the Group’s operations, financial position and result. The Swedish Tax Agency may have the view that the Group has not made or accounted for transactions and tax decisions in accordance with applicable laws and case law. Any such decisions and changes could have a negative effect on the Group’ operations, financial position and result. Under the current rules a divestment of a real estate owning company is in general exempt from both stamp duty and capital gains taxation. On 31 March 2017, the Swedish government presented a law proposal that would affect the future taxation of real estate investments. The main rule in the law proposal imply that when the control over a real estate owning company cease, the real estate will, for tax purposes, be considered sold and bought back at market value. Therefore capital gains tax at 22% would be payable by the real estate owning company. Further, it was proposed to reduce the general stamp duty rate from 4.25% to 2% and to add a similar stamp duty burden upon a transaction of a real estate owning company. These potential changes will not enter into force before 1 July 2018 but at this stage it is uncertain if the proposal will be implemented at all. In June 2017, further legislative changes were suggested, mainly with the purpose of enacting the EU Anti-Tax Avoidance Directive into Swedish domestic legislation. One key proposal that will entail significant changes for Swedish real estate in...
Tax risk. The Fund has elected to be treated as a “regulated investment company” (a “RIC”) under the Code and intends each year to qualify and be eligible to be treated as such, so that it generally will not be subject to U.S. federal income tax on its net investment income or net short-term or long-term capital gains, that are distributed to shareholders. In order to qualify and be eligible for such treatment, the Fund must meet certain asset diversification tests, derive at least 90% of its gross income for such year from certain types of qualifying income, and distribute to its shareholders at least 90% of its “investment company taxable income” as that term is defined in the Code (which includes, among other things, dividends, taxable interest and the excess of any net short-term capital gains over net long-term capital losses, as reduced by certain deductible expenses). The Fund’s investment strategy will potentially be limited by its intention to continue qualifying for treatment as a RIC, and can limit the Fund’s ability to continue qualifying as such. The tax treatment of certain of the Fund’s investments under one or more of the qualification or distribution tests applicable to RICs is uncertain. An adverse determination or future guidance by the Internal Revenue Service (“IRS”) or a change in law might affect the Fund’s ability to qualify or be eligible for treatment as a RIC. Income and gains from certain of the Fund’s activities, including fees received in connection with the origination of loans, may not constitute qualifying income to a RIC for purposes of the 90% gross income test. If the Fund were to treat income or gain from a particular investment or activity as qualifying income and the income or gain were later determined not to constitute qualifying income and, together with any other nonqualifying income, caused the Fund’s nonqualifying income to exceed 10% of its gross income in any taxable year, the Fund would fail to qualify as a RIC unless it is eligible to and does pay a tax at the Fund level. If, in any year, the Fund were to fail to qualify for treatment as a RIC under the Code, and was ineligible to or did not otherwise cure such failure, the Fund would be subject to tax on its taxable income at corporate rates and, when such income is distributed, shareholders would be subject to further tax on such distributions to the extent of the Fund’s current or accumulated earnings and profits. Portfolio Turnover Risk The Investment Manager mana...
Tax risk. PFIC and CFC Risk There is also a risk that the Issuer will be treated as a passive foreign investment company (PFIC). Depending on the ultimate ownership of the Issuer, there is also a risk that the Issuer will be treated as a controlled foreign corporation. See “Certain U.S. Federal Income Tax Considerations” below. Changes in Tax Law and/or the Identity of Shareholder; No Gross-Up in Respect of Notes All payments made by the Issuer under the Notes will be made without any deduction or withholding for or on account of any tax unless such deduction or withholding is required by any applicable law, as modified by the practice of any relevant governmental revenue authority, then in effect. Although the Issuer anticipates that, based on the initial composition of Noteholders, under current law no withholding tax or deduction will be imposed on the payments of interest or the return of capital on the Notes, there can be no assurance that, as a result of any change in any applicable law, treaty, rule, regulation, or interpretation thereof (whether by official or informal means) or a change in the composition of the Noteholders, the payments on the Notes would not in the future become subject to withholding taxes or deductions. In the event that any withholding tax or deduction is imposed on payments of interest or other payments on the Notes, the Issuer will not “gross-up” payments to the Noteholders. Changes in Tax Law; Imposition of Tax on the Issuer Although none are anticipated, the Issuer may, from time to time, take tax positions that may be subject to challenge by the Internal Revenue Service (the “IRS”) or by other relevant governmental revenue C-12Exhibit C authority. If the IRS or another governmental revenue authority do challenge such a position and they are successful, there may be substantial retroactive taxes, plus interest and possibly penalties. The Issuer intends to operate so as not to be subject to U.S. federal income tax or Irish tax under current law. However, there can be no assurance that the Issuer will not in the future be subject to tax by the United States, Ireland, or some other jurisdiction. The imposition of any such tax on the Issuer would materially affect the Issuer’s net income. The Issuer intends to qualify for the benefits of the tax treaty between the U.S. and Ireland. If the IRS successfully asserts that the Issuer does not benefit from the tax treaty between the U.S. and Ireland and imposes U.S. taxation on the income of...
