PFIC Status definition

PFIC Status the Issuer was not a "passive foreign investment company" ("PFIC") as defined in Section 1297 of the United States Internal Revenue Code of 1986, as amended, for its most recently completed taxable year and, based on the Issuer's current projected income, assets and activities, the Issuer does not expect to be classified as a PFIC for any subsequent taxable year;
Sample 1

Examples of PFIC Status in a sentence

  • Such gain generally would be taxable in a manner comparable to that discussed under "PFIC Status" at (v) above.

  • Taxation of capital gains Subject to the discussion on "PFIC Status" at (v) below, upon the sale or exchange of a New CAT Share or a New CAT ADS, a US Holder generally will recognise capital gain or loss for US federal income tax purposes in an amount equal to the difference between the amount realized and the adjusted tax basis in the New CAT Share or the New CAT ADS.

  • Taxation of dividends This discussion of the taxation of dividends is subject to the discussion on "PFIC Status" at (v) below.

  • Any gain would generally be taxable in a manner comparable to that discussed under "PFIC Status" at (v) above.

  • Any gain realized on the exchange would be subject to the excess distribution rules discussed below under “PFIC Rules and PFIC Status of CFCL”, unless a U.S. Holder has made a mark-to-market election, also discussed below under “PFIC Rules and PFIC Status of CFCL”.

  • PFIC Status of AurizonThe tax consequences of the Exchange to a particular U.S. Holder will depend on whether Aurizon was a passive foreign investment company (a “PFIC”) during any year in which a U.S. Holder owned Aurizon Shares.

  • Potential Application of Passive Foreign Investment Company Provisions AerCap's PFIC Status Although it has not yet made any determination, AerCap does not expect to be classified as PFIC for the year ended December 31, 2009.

  • Possible PFIC Status Shareholders who are U.S. taxpayers should be aware that the Corporation may be a passive foreign investment company (“PFIC”) for the current fiscal year; and may have been a PFIC in prior years or may become a PFIC in the future.

  • A U.S. Holder’s initial aggregate tax basis in the Trust Units received would be equal to the fair market value of the Trust Units (determined as of the Effective Date), and the U.S. Holder’s holding period in the Trust Units received would begin on the day after the Effective Date.A U.S. Holder that has made a timely QEF Election, also discussed below under “PFIC Rules and PFIC Status of CFCL”, would not be subject to these gain recognition rules.

  • PFIC Rules and PFIC Status of CFCLCertain adverse U.S. federal income tax rules could apply to U.S. Holders owning shares of a PFIC.

Related to PFIC Status

  • Domain Status clientDeleteProhibited Domain Status: clientRenewProhibited Domain Status: clientTransferProhibited Domain Status: serverUpdateProhibited Registrant ID: 5372808-ERL Registrant Name: EXAMPLE REGISTRANT Registrant Organization: EXAMPLE ORGANIZATION Registrant Street: 000 XXXXXXX XXXXXX Xxxxxxxxxx Xxxx: ANYTOWN Registrant State/Province: AP Registrant Postal Code: A1A1A1 Registrant Country: EX

  • Active status means (i) for employees, the absence of any interruption or termination of service as an employee, (ii) for Directors, that the Director has not been removed from the Board for cause (as determined by the Company’s shareholders), and (iii) for Consultants, the absence of any interruption, expiration, or termination of such person’s consulting or advisory relationship with the Company or any Subsidiary or the occurrence of any termination event as set forth in such person’s Award Agreement. Active Status shall not be considered interrupted (A) for an employee in the case of sick leave, maternity leave, infant care leave, medical emergency leave, military leave, or any other leave of absence properly taken in accordance with the policies of the Company or any applicable Subsidiary as may be in effect from time to time, and (B) for a Consultant, in the case of any temporary interruption in such person’s availability to provide services to the Company or any Subsidiary which has been granted in writing by an authorized officer of the Company. Whenever a mandatory severance period applies under applicable law with respect to a termination of service as an employee, Active Status shall be considered terminated upon such Employee’s receipt of notice of termination in whatever form prescribed by applicable law.

  • B-BBEE status level of contributor” means the B-BBEE status of an entity in terms of a code of good practice on black economic empowerment, issued in terms of section 9(1) of the Broad- Based Black Economic Empowerment Act;

  • Inactive status means the status of a practitioner licensed or registered pursuant to Iowa Code chapter 153 who is not currently engaged in the practice of dentistry, dental hygiene, or dental assisting in the state of Iowa and who has paid the required renewal fee but who has not met the requirements for continuing education.

  • Change in Status means any of the events described below, as well as any other events included under subsequent changes to Code section 125 or regulations issued thereunder, which the Plan Administrator, in its sole discretion and on a uniform and consistent basis, determines are permitted under IRS regulations and under this Plan.

  • Taxable Event means any change in control or other event which triggers the imposition of any Excise Tax on any Payment.

  • Level VI Status exists at any date if, on such date, the Borrower has not qualified for Level I Status, Level II Status, Level III Status, Level IV Status or Level V Status.

  • PFIC means a passive foreign investment company as defined in the Code.

  • Level I Status exists at any date if, as of the last day of the fiscal quarter of the Borrower referred to in the most recent Financials, the Leverage Ratio is less than 1.00 to 1.00.

  • Level IV Status exists at any date if, on such date, (i) the Borrower has not qualified for Level I Status, Level II Status or Level III Status and (ii) the Borrower's Xxxxx'x Rating is Baa3 or better or the Borrower's S&P Rating is BBB- or better.

  • REIT Status means, with respect to any Person, (a) the qualification of such Person as a real estate investment trust under the provisions of Sections 856 et seq. of the Code and (b) the applicability to such Person and its shareholders of the method of taxation provided for in Sections 857 et seq. of the Code.

  • Level II Status exists at any date if, on such date, (i) the Borrower has not qualified for Level I Status and (ii) the Borrower's Xxxxx'x Rating is Baa1 or better or the Borrower's S&P Rating is BBB+ or better.

  • Level V Status exists at any date if, on such date, the Borrower has not qualified for Level I Status, Level II Status, Level III Status or Level IV Status.

  • Level III Status exists at any date if, on such date, (i) the Borrower has not qualified for Level I Status or Level II Status and (ii) the Borrower's Xxxxx'x Rating is Baa2 or better or the Borrower's S&P Rating is BBB or better.

  • Tax-Free Status means the qualification of a Distribution or any other transaction contemplated by the IRS Ruling or any Tax Opinion as a transaction in which gain or loss is not recognized, in whole or in part, and no amount is included in income, including by reason of Distribution Taxes, for U.S. federal, state, and local income tax purposes (other than intercompany items, excess loss accounts or other items required to be taken into account pursuant to Treasury Regulations promulgated under Section 1502 of the Code).

  • former Act means the Companies Act or the International Business Companies Act;

  • Health status-related factor means any of the following factors:

  • Controlled Group Liability means any and all liabilities (i) under Title IV of ERISA, (ii) under Section 302 of ERISA, (iii) under Sections 412 and 4971 of the Code, (iv) as a result of a failure to comply with the continuation coverage requirements of Section 601 et seq. of ERISA and Section 4980B of the Code, and (v) under corresponding or similar provisions of foreign laws or regulations.