Form 5471 definition

Form 5471 means the Form, as adopted by the IRS entitled, “Information Return of U.S. Persons With Respect to Certain Foreign Corporations” or any similar, successor Form as adopted by the IRS.
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Form 5471 is defined in Section 2.02(c).
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Form 5471 means the Form, as adopted by the IRS, entitled “Information Return of U.S. Persons With Respect to Certain Foreign Corporations” or any similar, successor Form as adopted by the IRS. “Form 8621” shall mean the Form, as adopted by the IRS, entitled “Return of a Shareholder of a Passive Foreign Investment Company or Qualified Electing Fund” or any similar, successor Form as adopted by the IRS. “Governmental Authority” shall mean any (a) national, federal, state, local, county, municipal, city, town, village, district, foreign, or other government or jurisdiction of any kind, character, or nature whatsoever, (b) governmental or quasi-governmental authority of any kind, character, or nature whatsoever (including, without limitation, any court, judge, tribunal, agency, branch, department, commission, board, bureau, official, administrator, regulator, legislator, instrumentality, arbitrator, or mediator), (c) multi-national organization or body, or (d) individual Person or body exercising, or entitled to exercise, any administrative, executive, judicial, legislative, police, regulatory, or taxing authority or power of any kind, character, or nature whatsoever. “Group” shall have the meaning assigned to such term in Section 13(d)(3) of the Securities Act. “Involuntary Basis” shall mean any act or omission after the date hereof which causes SOF to become a United States Shareholder other than by reason of the purchase or other voluntary acquisition of Shares by SOF or any of its Affiliates. “IRS” shall mean the United States Internal Revenue Service. “Legal Requirement” shall mean, with respect to any Person, any federal, state, local, municipal, foreign, international, multinational, or other administrative order, constitution, law, ordinance, principle of common law, regulation, statute, or treaty applicable to such Person. “Libor Rate” shall mean, the average daily rate of a fluctuating rate of interest equal to the three (3) month London interbank offered rate as published in the “Money Rates” section of The Wall Street Journal. “Notification” shall mean a writing containing any information required by this Shareholders’ Agreement to be communicated to any Person, which shall be sent in accordance with Section 9.2 hereof. “Order” shall mean any award, decision, injunction, judgment, order, ruling, subpoena, or verdict entered, issued, made, or rendered by any court, administrative agency, or other Governmental Authority or by any arbitrator. “Organizational D...
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Examples of Form 5471 in a sentence

  • The Company will comply with any obligation imposed on the Company to make any filing (including any filing on Internal Revenue Service Form 5471) as a result of any interest that the Company holds in a non-U.S. Person or any activities that the Company conducts outside of the U.S. and shall include in such filing any information necessary to obviate (to the extent possible) any similar obligation to which any shareholder would otherwise be subject with respect to such interest or such activity.

  • In addition, Subscriber understands that if Subscriber invests an amount equal to or exceeding $100,000 or purchases 10% or more of the total Class A shares offered in the Offering and Subscriber is a U.S. citizen, U.S. resident or U.S. entity, Subscriber may be required to file additional tax forms such as, but not limited to, IRS Form 926 and Form 5471.

  • The Depositor shall cause to be prepared and delivered to the Trustee or Co-Trustee an annual income statement for the Trust together with such other information as is necessary for the Holders of Certificates to make an effective qualified electing fund (or "QEF") election pursuant to section 1295 of the Code and to file IRS Form 5471 or any successor form.

  • Also, include country of incorporation or formation, if applicable.(b) Description of each class of stock held by shareholder.Note: This description should match the corresponding description entered in Schedule A, column (a).(c) Number of shares held atbeginning of annual accounting period(d) Number of shares held at end of annualaccounting period Form 5471 (Rev.

  • It is expected, however, that these issues will be alleviated in practice through the conclusion of IGAs. Comments also requested that the rules defining withholdable payment exclude payments that are reported by the withholding agent on Form 5471 or 5472 in order to alleviate duplicative reporting.

  • In addition, if the shareholder filed a Form 5471 for the Former PFIC for the election year, attach Schedule J (Form 5471).

  • If for any taxable year the filing of Form 5471 is necessary, upon the presentation of a completed Form 5471 to SOF by the Accounting Firm for any taxable year for filing with the IRS as provided in Section 4.1(a) above, the Company shall further certify that the Form 5471 is correct and complete.

  • Corporations are already required to file information about the income of all of their foreign subsidiaries with the federal government on IRS Form 5471.

  • Depending on the number of units held, acquired or disposed of by a U.S. Holder, the U.S. Holder may also be required to file an information return on IRS Form 5471 with the IRS.

  • If any additional amount of tax is later determined to be owed as a result of a challenge by the IRS as contemplated by Section 4.1(b) above or as a result of an amendment to the Form 5471 for any reason at the request or recommendation of the Accounting Firm, the Company shall make an additional shareholder distribution hereunder by no later than sixty (60) days following the remittance by SOF to the U.S. Treasury of such additional tax amount.

Related to Form 5471

  • IRS means the United States Internal Revenue Service.

  • Section 338 Forms means all returns, documents, statements, and other forms that are required to be submitted to any federal, state, local or foreign Taxing authority in connection with a Section 338(h)(10) Election, including, without limitation, any "statement of Section 338 Election" and IRS Form 8023 (together with any schedules or attachments thereto) that are required pursuant to Treasury regulations.

  • Income Tax Returns means all Tax Returns relating to Income Taxes.

  • Income Tax Return means any Tax Return relating to Income Taxes.

  • Tax Return means any return, declaration, report, claim for refund, or information return or statement relating to Taxes, including any schedule or attachment thereto, and including any amendment thereof.

  • Tax return preparer means any individual described in Section 7701(a)(36) of the Internal Revenue Code and 26 C.F.R. 301.7701-15 .

  • Internal Revenue Service means the United States Internal Revenue Service.

  • Tax Certification Forms means any forms or other documentation as may be issued or required by a Tax Authority or by us from time to time to confirm your tax status [or the tax status of a Connected Person].

  • Non-Income Tax Return means any Tax Return relating to Taxes other than Income Taxes.

  • Form W-8ECI means Form W-8ECI (Certificate of Foreign Person’s Claim for Exemption from Withholding of Tax on Income Effectively Connected with the Conduct of a Trade or Business in the United States) of the Department of the Treasury of the United States of America, and any successor form.

  • Federal Tax Certificate means the Issuer's Federal Tax Certificate dated as of the Issue Date, as the same may be amended or supplemented in accordance with the provisions thereof.

  • Tax Authorities means domestic or foreign tax, revenue, fiscal or monetary authorities.

  • United States Tax Compliance Certificate has the meaning specified in Section 3.01.

  • File “Filed,” or “Filing” means file, filed, or filing with the Bankruptcy Court or its authorized designee in the Chapter 11 Cases.

  • Consolidated federal income tax return means a consolidated return filed for federal income tax purposes pursuant to section 1501 of the Internal Revenue Code.

  • Reports means the reports described in Schedule B as well as any other reports or information required to be provided under the Enabling Legislation or this Agreement;

  • Rule 482 Statement means a document that contains the number of Securities issued, the offering price and any other items dependent upon the offering price, prepared in accordance with the provisions of Rule 482 of the 1933 Act, a copy of which shall be attached as Schedule D hereto. “Statutory Prospectus” as of any time means the prospectus relating to the Securities that is included in the Registration Statement immediately prior to that time, including any document incorporated by reference therein. Each preliminary prospectus and the prospectus filed as part of the effective Registration Statement or as part of any amendment thereto, or filed pursuant to Rule 497 under the 1933 Act, complied when so filed in all material respects with the Rules and Regulations and each preliminary prospectus and the Prospectus delivered to the Underwriters for use in connection with this offering was identical to the electronically transmitted copies thereof filed with the Commission pursuant to XXXXX, except to the extent permitted by Regulation S-T. If a Rule 462(b) Registration Statement is required in connection with the offering and sale of the Securities, the Fund has complied or will comply with the requirements of Rule 111 under the 1933 Act Rules and Regulations and Rule 3a of the Commission’s Internal and Other Procedures (“Rule 3a”) relating to the payment of filing fees thereof. The Fund, subject to the Registration Statement having been declared effective and the filing of the Prospectus under Rule 497, has taken all required action under the 1933 Act, the 1940 Act, the Securities and Exchange Act of 1934, as amended (the “1934 Act”) and the Rules and Regulations to make the public offering and consummate the sale of the Securities as contemplated by this Agreement.

  • Tax Package has the meaning assigned in Section 6.01(b);

  • Tax Returns means any and all reports, returns, declarations, claims for refund, elections, disclosures, estimates, information reports or returns or statements required to be supplied to a taxing authority in connection with Taxes, including any schedule or attachment thereto or amendment thereof.

  • Form W-8BEN means Form W-8BEN (Certificate of Foreign Status of Beneficial Owner for United States Tax Withholding) of the Department of Treasury of the United States of America, and any successor form.

  • Filed means hand delivered to the Commission's office in Richmond or any regional office

  • Section 336(e) Election has the meaning set forth in Section 7.06.

  • Tax means any tax, levy, impost, duty or other charge or withholding of a similar nature (including any penalty or interest payable in connection with any failure to pay or any delay in paying any of the same).

  • Local health department means the same as that term is defined in Section 26A-1-102.

  • Database application form means the application form required by the Hibiscus Coast Municipality to be filled in by the successful tenderer, following the award of the contract, for inclusion on the HCM database before payment is made.

  • R (k) means the Reference Price on the respective Observation Date (k).