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.

  • 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.

  • 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”.

  • Hamilton, Comments on Application of the PFIC Rules to Trusts, 93 TNT 20-52 (Dec.

  • 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").

  • 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.

  • However, in its popular sense, an ‘apocalypse’ is not typically understood as a revelation, but as a sudden calamity, or ‘the end of the world as we know it’.

Related to PFIC Rules

  • HKIAC Rules shall have the meaning ascribed to it in Section 10.13(a).

  • HIPAA Rules means the Privacy, Security, Breach Notification, and Enforcement Rules at 45 CFR Part 160 and Part 164.

  • CySEC Rules means the Rules, Directives, Regulations, Guidance notes, opinions or recommendations of CySEC.

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

  • JAMS Rules has the meaning assigned thereto in Section 13 hereof.

  • FSA Rules meanss the rules, guidance, principles and codes comprised in the Handbook of Rules and Guidance issued by the FSA.

  • M&A Rules means the Provisions on Merging and Acquiring Domestic Enterprises by Foreign Investors, which was promulgated by six Governmental Agencies, namely, the Ministry of Commerce, the State-owned Assets Supervision and Administration Commission, the State Administration for Taxation, the State Administration for Industry and Commerce, the China Securities Regulatory Commission (the “CSRC”), and the State Administration of Foreign Exchange, on August 8, 2006 and became effective on September 8, 2006, as amended by the Ministry of Commerce on June 22, 2009.

  • ICC Rules means the Rules of Arbitration of the International Chamber of Commerce in effect on the date the applicable arbitration proceeding begins.

  • FCC Rules means the rules, regulations, orders and promulgated and published policy statements of the FCC.

  • PPB Rules means the rules of the Procurement Policy Board as set forth in Title 9 of the Rules of the City of New York (“RCNY”), § 1-01 et seq.

  • Criminal Procedure Act means the Criminal Procedure Act, 1977 (Act No. 51 of 1977);

  • House Rules the rules described in the Residents’ Handbook as listed in Schedule 4 and any revisions issued by the Landlord/Agent from time to time, for the benefit of the Building;

  • Applicable Laws/ Rules means the laws/ Rules of Islamic Republic of Pakistan/Punjab, as they may be issued and enforced from time to time.

  • 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.

  • Risk Retention Rules means the joint final rule that was promulgated to implement the Risk Retention Requirements (which such joint final rule has been codified, inter alia, at 17 C.F.R. § 246), as such rule may be amended from time to time, and subject to such clarification and interpretation as have been provided by the Office of the Comptroller of the Currency, the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, the Federal Housing Finance Agency, the Commission and the Department of Housing and Urban Development in the adopting release (79 Fed. Reg. 77601 et seq.) or by the staff of any such agency, or as may be provided by any such agency or its staff from time to time, in each case, as effective from time to time as of the applicable compliance date specified therein.

  • Arbitration Rules means the AAA’s Commercial Arbitration Rules and Mediation Procedures.

  • U.S. Risk Retention Rules means the federal interagency credit risk retention rules, codified at 17 C.F.R. Part 246.

  • AIM Rules means the rules published by the London Stock Exchange governing admission to AIM and the regulation of AIM companies as amended or re-issued from time to time;

  • Organic rules means the public organic record and private organic rules of an entity.

  • CCASS Rules means the General Rules of CCASS and the CCASS Operational Procedures in effect from time to time;

  • General Data Protection Regulation GDPR" means regulation (EU) 2016/679 of the European parliament and of the council as amended from time to time.

  • PRA Rules means the Rules included within the PRA handbook issued by the PRA.

  • Mediation Rules As defined in Section 2.03(h)(i).

  • UNCITRAL Arbitration Rules means the arbitration rules of the United Nations Commission on International Trade Law.

  • Benchmarks Regulation means Regulation (EU) 2016/1011 of the European Parliament and of the Council of 8 June 2016 on indices used as benchmarks in financial instruments and financial contracts or to measure the performance of investment funds and amending Directives 2008/48/EC and 2014/17/EU and Regulation (EU) No 596/2014;

  • Operating Rules means the operating rules of a CS Facility regulating the settlement, clearing and registration of uncertificated shares as amended, varied or waived (whether in respect of the Company or generally) from time to time which shall only apply to the Company during the Listed Period;