United States Taxation. The Manager shall take no action that would cause the Company to be deemed to be engaged in a trade or business in the United States and which would cause the Company to be found to be a U.S. taxpayer.
United States Taxation. For a discussion of certain material U.S. federal income tax consequences of owning the notes, please see the section “Tax Consequences—United States Taxation” in the accompanying prospectus and any applicable tax consequences discussed in the applicable pricing supplement.
United States Taxation. Where AHFC is required to make payment of the principal of and interest on a Note, AHFC will, subject to the exceptions and limitations set forth below, pay as additional interest such additional amounts (the “U.S. Additional Amounts”) as are necessary in order that the net amount of such payment by AHFC or any Paying Agent of the principal of and interest on a Note to a holder who is a United States Alien, after deduction for any present or future tax, assessment or governmental charge of the United States (as such term is defined below), or a political subdivision or authority thereof or therein, imposed by withholding with respect to the payment, will not be less than the amount provided for in such Note to be then due and payable; provided, however, that the foregoing obligation to pay U.S. Additional Amounts shall not apply:
(i) to any tax, assessment or governmental charge that would not have been so imposed but for the existence of any present or former connection between such holder (or between a fiduciary, settlor, beneficiary, member or shareholder of, or holder of power over, such holder, if such holder is an estate, trust, partnership or corporation) and the United States, including, without limitation, such holder (or such fiduciary, settlor, beneficiary, member, shareholder or holder of a power) being considered as:
(A) being or having been present or engaged in a trade or business in the United States or having had a permanent establishment therein;
(B) having a current or former relationship with the United States, including a relationship as a citizen or resident or being treated as a resident thereof;
(C) being or having been, for United States federal income tax purposes, a “controlled foreign corporation”, a “passive foreign investment company”, a corporation that has accumulated earnings to avoid United States federal income tax or a private foundation or other tax-exempt organisation; or
(D) an actual or a constructive “10 per cent. shareholder” of AHFC, as defined in Section 871(h)(3) of the United States Internal Revenue Code of 1986, as amended (the “Code”);
(ii) to any holder who is a fiduciary or partnership or other than the sole beneficial owner of the Note but only to the extent that a beneficiary or settlor with respect to such fiduciary or member of such partnership or a beneficial owner of the Note would not have been entitled to the payment of a U.S. Additional Amount had such beneficiary, settlor, member or beneficial own...
United States Taxation. (a) No Group Company that is a Subsidiary incorporated in the United States will be required to include any item of income in, or exclude any item of deduction from, taxable income for any taxable period (or portion thereof) ending after Completion as a result of any:
(i) change in method of accounting for a taxable period ending on or prior to Completion;
(ii) use of an improper method of accounting for a taxable period ending on or prior to Completion;
United States Taxation. (a) The US Subsidiary has not waived any statute of limitations in respect of Taxes or agreed to any extension of time with respect to a Tax assessment or deficiency.
