Examples of Holding Company Class B Stock in a sentence
If a U.S. Holder has held the Holding Company Class A Stock or Holding Company Class B Stock for one year or less, such capital gain or loss will be short-term capital gain or loss taxable as ordinary income at your marginal income tax rate.
Dividends paid by Holding Company will not be eligible for preferential rates applicable to QDI, as described below.To the extent a distribution exceeds Holding Company’s current and accumulated earnings and profits, it will be treated first as a non-taxable return of capital to the extent of U.S. Holder’s adjusted tax basis in the Holding Company Class A Stock or Holding Company Class B Stock, and thereafter as capital gain.
The holders of Holding Company Class A Stock will be entitled to elect six members of the Holding Company Board of Directors, and the holders of Holding Company Class B Stock will be entitled to elect three members of the Holding Company Board of Directors, including the chairperson of the Holding Company Board of Directors.
Such gain or loss will be capital gain or loss.If a U.S. Holder has held the Holding Company Class A Stock or Holding Company Class B Stock for more than one year at the time of disposition, such capital gain or loss will be long-term capital gain or loss.
Any amendment of any of the Transaction Documents which would adversely affect the rights of the holders of Holding Company Class B Stock described in the Plan.
Holding Company Class A Stock and Holding Company Class B Stock will initially not be traded on an established securities market.
Among other requirements, dividends generally will be treated as QDI if either (i) the Holding Company Class A Stock or Holding Company Class B Stock are readily tradable on an established securities market in the United States, or (ii) Holding Company is eligible for the benefits of a comprehensive income tax treaty with the United States which includes an information exchange program and which is determined to be satisfactory by the U.S. Treasury.
U.S. HoldersSubject to the discussion regarding the PFIC and CFC rules below, a U.S. Holder that actually or constructively receives a distribution on Holding Company Class A Stock or Holding Company Class B Stock must include the distribution in gross income as a taxable dividend on the date of its receipt of the distribution, but only to the extent of Holding Company’s current or accumulated earnings and profits, as calculated under U.S. federal income tax principles.
On the other hand, to the extent the combined value received in New Secured Notes, Holding Company Class A Stock or Holding Company Class B Stock by such Dominican Holder is lower than the value of the Unsecured Financial Claim as of the date of acquisition by the Dominican Holder, adjusted for inflation, then the Dominican Holder will recognize a loss.
However, trading of Holding Company Class A Stock and Holding Company Class B Stock might be contemplated in the future, whether pursuant to the Registration Rights Agreement or otherwise.