Personal Holding Company definition

Personal Holding Company means a personal holding Company that is either wholly owned, or controlled by, any director, executive officer, employee or Consultant of the Company or its Affiliates, and the shares of which are held directly or indirectly by any such person or the person s spouse, minor children and/or minor grandchildren;

Personal Holding Company means a company of which 100% of the voting shares are beneficially owned, directly or indirectly, by a director, officer or employee of, or consultant to, the Corporation or its Subsidiaries and such entity shall be bound by the Plan in the same manner as if the Options were held directly;

Personal Holding Company means a personal holding corporation that is either wholly owned, or controlled by, the Participant, and the shares of which are held directly or indirectly by any of the Participant or the Participant’s spouse, minor children and/or minor grandchildren;

Examples of Personal Holding Company in a sentence

• The Depositary shall not incur any liability for any tax consequences that may be incurred by Holders and Beneficial Owners on account of their ownership of the ADSs, including without limitation, tax consequences resulting from the Company (or any of its subsidiaries) being treated as a "Foreign Personal Holding Company," or as a "Passive Foreign Investment Company" (in each case as defined in the U.S. Internal Revenue Code and the regulations issued thereunder) or otherwise.

• The Depositary shall not incur any liability for any tax consequences that may be incurred by Holders and Beneficial Owners on account of their ownership of the American Depositary Shares, including without limitation, tax consequences resulting from the Company (or any of its subsidiaries) being treated as a "Foreign Personal Holding Company," or as a "Passive Foreign Investment Company" (in each case as defined in the U.S. Internal Revenue Code and the regulations issued thereunder) or otherwise.

• A major type of taxable Subpart F offshore income is referred to in the tax code as Foreign Personal Holding Company Income (FPHC).55 It consists of passive income such as dividends, royalties, rents and interest.56 One example of FPHC income that is taxable under Subpart F is a dividend payment made from a lower tiered to a higher tiered CFC.

• Apple’s Offshore Distribution Structure AppleHolding Company (AOI)Foreign Personal Holding Company IncomeDividendsDividendsForeign Base Company Sales IncomeGoodsConsumers Offshore Distribution SubsidiariesIreland/ Singapore Apple Sales Int’lIrelandAOE Third Party MFRChina Source: Prepared by Subcommittee based on interviews with Apple employees 128 Information supplied to Subcommittee by Apple, APL-PSI-000386.129 IRC Section 954(d).130 IRC Section 954(c).

• In the Convention, unlike some U.S. treaties, the Accumulated Earnings Tax and the Personal Holding Company Tax are covered taxes because they are income taxes and they are not otherwise excluded from coverage.

• The Depositary shall not incur any liability for any tax consequences that may be incurred by Holders and Beneficial Owners on account of their ownership of the ADSs, including, without limitation, tax consequences resulting from the Company (or any of its subsidiaries) being treated as a "Foreign Personal Holding Company," or as a "Passive Foreign Investment Company" (in each case as defined in the U.S. Internal Revenue Code and the regulations issued thereunder) or otherwise.

• Schedule N (Form 5471) (Return of Officers, Directors, and 10% or More Shareholders of a Foreign Personal Holding Company) 13.

• The Depositary shall not incur any liability for any tax consequences that may be incurred by holders and Owners on account of their ownership of the American Depositary Shares, including without limitation, tax consequences resulting from the Company (or any of its subsidiaries) being treated as a "Foreign Personal Holding Company," or as a "Passive Foreign Investment Company" (in each case as defined in the U.S. Internal Revenue Code and the regulations issued thereunder) or otherwise.

• The Depositary shall not incur any liability for any tax consequences that may be incurred by holders and Owners on account of their ownership of the American Depositary Shares, including without limitation, tax consequences resulting from the Issuer (or any of its subsidiaries) being treated as a "Foreign Personal Holding Company," or as a "Passive Foreign Investment Company" (in each case as defined in the U.S. Internal Revenue Code and the regulations issued thereunder) or otherwise.

• Model A is similar in approach to the U.S. Foreign Personal Holding Company rules of Subpart F.

More Definitions of Personal Holding Company

Personal Holding Company means a personal holding Company that is either wholly owned, or controlled by, any director, executive officer, employee or Consultant of the Company or its Affiliates, and the shares of which are held

Personal Holding Company means a company of which is wholly owned directly by a director, officer or employee of, or consultant to, the Corporation or its Subsidiaries;

Personal Holding Company means a personal holding corporation that is either wholly owned, or controlled by, the Optionee, and the shares of which are held directly or indirectly by any of the Optionee or the Optionee’s spouse, minor children and/or minor grandchildren;

Personal Holding Company means a corporation controlled by an Eligible Person, the shares of which are owned, directly or indirectly, by such Eligible Person, and/or the spouse, minor children and/or minor grandchildren of such Eligible Person;

Personal Holding Company. — means, in relation to a Service Provider, a body corporate, the issued and outstanding voting securities of which are beneficially owned, directly or indirectly, by the Service Provider and/or the spouse, children and/or grandchildren of the Service Provider.