PFIC Rules definition

PFIC Rules means 26 U.S.C. §§ 1291-98 or any similar statutes hereafter enacted having substantially the same purpose and effect as such Code Sections.
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PFIC Rules means 26 U.S.C. §§ 1291-98 or any similar statutes hereafter enacted having substantially the same purpose and effect as such Code Sections. “Piggyback Notice” shall have the meaning as set forth in Section 6.3. “Preemptive Notice” shall mean a Notification which shall describe fully: (i) the terms, including the price, of the proposed Transfer; (ii) the number of Shares equal to SOF’s Pro Rata Amount of such Shares being sold; (iii) method of proposed Transfer; and (iv) the proposed closing date of the Transfer. “Preemptive Right” shall have the meaning assigned to such term in Section 7.1. “Preemptive Shares” shall have the meaning assigned to such term in Section 7.1. “Proceeding” shall mean any formal action, arbitration, mediation, dispute resolution, audit, hearing, investigation, litigation, or suit (whether civil, criminal, administrative, investigative) in, commenced, brought, conducted, or heard by or before, or otherwise involving, any judge, court, arbitrator, mediator, or Governmental Authority of any kind, character, or nature, the results of which shall be legally binding on the parties subject thereto. “Process Agent” shall have the meaning set forth in Section 9.3. “Prohibited Transferees” has the meaning set forth in Section 9.7. “Pro Rata Amount” shall have the meaning set forth in Section 7.1. “Prospectus” shall mean the prospectus included in a Registration Statement (including, without limitation, a prospectus that includes any information previously omitted from a prospectus filed as part of an effective registration statement in reliance upon Rule 430A promulgated under the Securities Act), as amended or supplemented by any prospectus supplement, with respect to the terms of the offering of any portion of the Registrable Securities covered by a Registration Statement, and all other amendments and supplements to the Prospectus, including post-effective amendments, and all material incorporated by reference or deemed to be incorporated by reference in such Prospectus. “Put Closing” shall have the meaning set forth in Section 6.6. Appendix A to Amended and Restated Shareholders’ Agreement
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Examples of PFIC Rules in a sentence

  • In conclusion, we submit that our proposals are administrable, are fair, meet the goal of Congress when it adopted the PFIC rules of delaying tax to U.S. beneficiaries until they receive a distribution, and integrate the operation of the PFIC Rules with Subchapter J.

  • Applicability Dates Relating to the General PFIC Rules These regulations are proposed to apply to taxable years of United States persons that are shareholders in certain foreign corporations beginning on or after the date of filing of the Treasury Decision adopting these rules as final regulations in the Federal Register.

  • Effects of PFIC Rules on the Domestication Section 1291(f) of the Code requires that, to the extent provided in Treasury Regulations, a U.S. person who disposes of stock of a PFIC recognizes gain notwithstanding any other provision of the Code.

  • Subject to the discussion under "PFIC Rules," upon the sale or other taxable disposition of our common shares, a US Holder generally will recognize capital gain or loss in an amount equal to the difference between the US dollar value of cash received plus the fair market value of any property received and such US Holder's tax basis in such common shares sold or otherwise disposed of.

  • Other PFIC Rules Certain additional adverse rules will apply with respect to a U.S. Holder if the Company is a PFIC, regardless of whether such U.S. Holder makes a QEF Election or a Mark-to-Market Election.

  • Effects of PFIC Rules on the Domestication Section 1291(f) of the Code requires that, to the extent provided in U.S. Treasury regulations, a U.S. Holder that disposes of stock of a PFIC recognizes gain notwithstanding any other provision of the Code.

  • In order to avoid fully the adverse U.S. federal income tax rules described under "—Default PFIC Rules," U.S. Holders desiring QEF Election treatment also must make a QEF Election for any Subsidiary PFIC.

  • Ownership and Disposition of the Shares if the Company is Not a PFIC The discussion below would apply to a U.S. Holder if the Company is not a PFIC, or if the Company ceases to be a PFIC (and the U.S. Holder is not a Non-Electing U.S. Holder that would continue to be treated as holding stock of a PFIC as described under "—Default PFIC Rules").

  • Subject to the discussion under "PFIC Rules," a US Holder that receives a distribution, including a constructive distribution, as described below, with respect to common shares will be required to include the amount of such distribution in gross income as a dividend (without reduction for any Canadian income tax withheld from such distribution) to the extent of our current and accumulated "earnings and profits," as computed for US federal income tax purposes.

  • InformationConcerning the Arrangement – Certain United States Federal Income Tax Considerations – Ownership and Disposition of Wallbridge Shares – Default PFIC Rules Under Section 1291 of the U.S. Tax Code”.

Related to PFIC Rules

  • FCA Rules means the Rules included within the FCA Handbook issued by the FCA.

  • Model Rules means the State of Oregon’s Attorney General’s model rules of procedure for Public Contracting, which are set forth in OAR Chapter 137, divisions 46, 47, 48, and 49, and required under ORS 279A.065.