Form 8621 definition

Form 8621 means 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.
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Form 8621 means 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 Documents” shall mean (a) the articles or certificate of incorporation, memorandum of association and the bye-laws of a corporation; (b) the partnership agreement or Appendix A to Amended and Restated S...
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Examples of Form 8621 in a sentence

  • Check box 3 and enter the amount and “ECR” in the space next to that box.• Any tax from Form 8621, line 16e,relating to a section 1291 fund.

  • In general, all shareholders required to file Form 8621 under section 1298(f) and the regulations thereunder must complete Part I.

  • A share- holder makes the deemed dividend election by filing Form 8621 and the at- tachment to Form 8621 described in paragraph (c)(5)(ii) of this section with the return of the shareholder for the election year, reporting the deemed dividend as an excess distribution pur- suant to section 1291(a)(1), and paying the tax and interest due on the excess distribution.

  • A U.S. Holder makes a QEF election with respect to any year that we are a PFIC by filing IRS Form 8621 with the U.S. Holder’s U.S. federal income tax return.

  • This is demonstrated by attaching a statement to Form 8621 that includes the information listed under Attachments for Election C, earlier.

  • A shareholder that makes the deemed dividend election after the due date of the return (determined without regard to extensions) for the election year must pay additional in- terest, pursuant to section 6601, on the amount of underpayment of tax for that year.(ii) Attachment to Form 8621.

  • An electing shareholder that realizes a loss shall report the loss on Form 8621, but shall not recognize the loss.

  • Fill in the amount of excess distribution from a passive foreign investment company which has not been included in federal taxable income (see federal Form 8621 or 8621-A).

  • See TD 9806.Shareholders filing a joint return may file a single Form 8621 with respect to a single PFIC in which each joint filer owns an interest.Shareholders that are the first U.S. person in the chain of ownership.

  • Include on line 13 the cooperative's share of distributions from a section 1291 fund from Form 8621, to the extent that the amounts are taxed as dividends under section301.

Related to Form 8621

  • 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.

  • IRS means the United States Internal Revenue Service.

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

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

  • 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.

  • Income Tax Returns means all Tax Returns 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.

  • Form 8-K As defined in the Pooling and Servicing Agreement.

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

  • Form 2106 means internal revenue service form 2106 filed by a taxpayer pursuant to the Internal Revenue Code.

  • 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 .

  • Form 10-D Disclosure Item means, with respect to any Person, (a) any legal proceedings pending against such Person or of which any property of such Person is then subject, or (b) any proceedings known to be contemplated by governmental authorities against such Person or of which any property of such Person would be subject, in each case that would be material to the Noteholders.

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

  • Federal internal revenue code means the internal revenue code of the United States in effect on the last day of the taxpayer's tax year.

  • Form 4224 means Form 4224 (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 (or in relation to either such Form such successor and related forms as may from time to time be adopted by the relevant taxing authorities of the United States of America to document a claim to which such Form relates).

  • Allocation Statement has the meaning set forth in Section 2.5(a).

  • Form 10-K Certification As defined in Section 4.03(e).

  • Short Form Notice means the Short Form Notice substantially in the form as

  • method statement means a written submission by the Contractor to the Project Manager in response to this EMPr or a request by the Project Manager and ECO. The method statement must set out the equipment, materials, labour and method(s) the Contractor proposes using to carry out an activity identified by the Project Manager when requesting the Method Statement. This must be done in such detail that the Project Manager and ECO is able to assess whether the Contractor's proposal is in accordance with this specification and/or will produce results in accordance with this specification;

  • Internal Revenue Code means the Internal Revenue Code of 1986, as amended, or any successor statute.

  • Affidavit of Small Business Enterprise Certification means the fully completed, signed, and notarized affidavit that must be submitted with an application for SBE certification. Representations and certifications made by the applicant in this Affidavit are made under penalty of perjury and will be used and relied upon by City to verify SBE eligibility and compliance with SBE certification and documentation requirements.

  • Tax Code means the Internal Revenue Code of 1986, as amended.

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

  • Tax Commissioner means the tax commissioner appointed under section 121.03 of the Revised Code.

  • Revenue Commissioners means the Revenue Commissioners of Ireland;

  • Income Tax Act means the Income Tax Act (Canada), as amended from time to time;