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.
United States shareholder means a “United States shareholder” within the meaning of Section 951 of the Code.
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. 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.
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.
For pur- poses of this section, a United States shareholder is a person described in sec- tion 951(b) or section 953(c).
During this period the Equipment must remain operational and Lessee must provide adequate electrical power, lighting, heat, water and compressed air, necessary to permit Lessor to demonstrate the Equipment to any potential buyer.
Third party interest expense of the related United States shareholder equal to the amount of interest income received on excess related person in- debtedness as determined in step 4 shall be allocated among the various separate limitation categories in pro- portion to the relative aggregate amount of related controlled foreign corporation obligations held by the re- lated United States shareholder in each such category, as determined under step 5.
More Definitions of United States shareholder
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. 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, 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 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 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 any Subsidiary of STERIS plc that, with respect to a Select Group Company, constitutes a “United States shareholder” within the meaning of Section 951(b) of the Code.