United States shareholder definition

United States shareholder means a “United States shareholder” within the meaning of Section 951 of the Code.

Examples of United States shareholder in a sentence

Subpart F income is included in the gross income of a United States shareholder of a con- trolled foreign corporation under the rules of section 951 and the regulations thereunder, and thus is subject to cur- rent taxation under section 1 or 11 of the Code.
The aggregate amount of related controlled foreign corporation obligations held by the related United States shareholder in each limitation category equals the sum of the value of all such obligations in each limitation category.
If a significant holder is a controlled foreign corporation (within the meaning of section 957), each United States shareholder (within the meaning of section 951(b)) with respect thereto must include this statement on or with its return.
For pur- poses of this section, a United States shareholder is a person described in sec- tion 951(b) or section 953(c).
In the case of a controlled foreign cor- poration that is a look-through entity, the tax attributes to be taken into ac- count are those of any person that is a United States shareholder (as defined in paragraph (b)(2)(iii)(d)(5) of this sec- tion) of the controlled foreign corpora- tion, or, if the United States share- holder is a look-through entity, a United States person that owns an in- terest in such shareholder directly or indirectly through one or more look- through entities.

United States shareholder means, with respect to any foreign corporation, a United States person who owns, or is considered as owning, 10 percent or more of the total combined voting power of all classes of stock entitled to vote of such foreign corporation. Regulations; (b) the Financial Institution is wholly owned, directly or indirectly, by a Reporting U.S. Financial Institution that agrees to act, or requires an affiliate of the Financial Institution to act, as a sponsoring entity for the Financial Institution; and (c) the Financial Institution shares a common electronic account system with the sponsoring entity that enables the sponsoring entity to identify all Account Holders and payees of the Financial Institution and to access all account and customer information maintained by the Financial Institution including, but not limited to, customer identification information, customer documentation, account balance, and all payments made to the Account Holder or payee.

United States shareholder has the meaning set forth in Section 951(b) of the Code.

United States shareholder without creating an investment in “US property” (and a “United States shareholder” could pledge more than 66% of the voting stock of its “controlled foreign corporation”), then the affected Foreign Subsidiary (and, to the extent affected, each of its Subsidiaries ) shall not be an Excluded Foreign Subsidiary.

United States shareholder means, with respect to any foreign corporation, a United States person who owns, or is considered as owning, 10 percent or more of the total combined voting power of all classes of stock entitled to vote of such foreign corporation. the United Kingdom that is not a qualified intermediary, withholding foreign partnership, or withholding foreign trust pursuant to relevant U.S. Treasury Regulations; (b) the Financial Institution is wholly owned, directly or indirectly, by a Reporting U.S. Financial Institution that agrees to act, or requires an affiliate of the Financial Institution to act, as a sponsoring entity for the Financial Institution; and (c) the Financial Institution shares a common electronic account system with the sponsoring entity that enables the sponsoring entity to identify all Account Holders and payees of the Financial Institution and to access all account and customer information maintained by the Financial Institution including, but not limited to, customer identification information, customer documentation, account balance, and all payments made to the Account Holder or payee.

United States shareholder means, with respect to any foreign corporation, a United States person who owns, or is considered as owning, 10 percent or more of the total combined voting power of all classes of stock entitled to vote of such foreign corporation, or 10 percent or more of the total value of shares of all classes of stock of such foreign corporation. Financial Institution that agrees to act, or requires an affiliate of the Financial Institution to act, as a sponsoring entity for the Financial Institution; and (c) the Financial Institution shares a common electronic account system with the sponsoring entity that enables the sponsoring entity to identify all Account Holders and payees of the Financial Institution and to access all account and customer information maintained by the Financial Institution including, but not limited to, customer identification information, customer documentation, account balance, and all payments made to the Account Holder or payee.

United States shareholder. A “U.S. Shareholder” is any U.S. person (including a partnership organized in the United States) that owns or is treated as owning 10% or more of the total voting power of a foreign corporation’s stock. The regulations generally measure the voting power of each class according to the percentage of the board of directors that the class can elect or replace and then divide the voting power of the class among the persons that own shares of that class. A U.S. person is treated as meeting the 10% threshold if that person owns 20% or more of the number of shares of a class of stock that has the power to elect a majority of the board of directors. The following rules are applied for the purpose of determining whether these thresholds are satisfied.

United States shareholder means any United States person (as defined in section 957(c) of the Code) that would be treated as a "United States shareholder" (within the meaning of section 951(b)) with respect to the Company.