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.