USRPHC definition

USRPHC means “United States real property holding corporation” as defined in Section 897(c)(2) of the Code, and Treasury Regulation Section 1.897-2(b).

USRPHC has the meaning assigned to it in Section 3.18(e).

USRPHC has the meaning set forth in Section 4.16.

Examples of USRPHC in a sentence

• The Company agrees to make determinations as to its status as a USRPHC, and will file statements concerning those determinations with the Internal Revenue Service, in the manner and at the times required under Reg.

• A mutual fund or ETF that is not subject to the USRPHC - related rules described above may distribute ordinary dividends which should be subject to 30% withholding tax.

• However, if the mutual fund or ETF that is sold is a USRPHC, then the gain is considered to be effectively connected with a U.S. trade or business and thus subject to U.S taxation, unless the mutual fund or ETF whose shares are sold is (a)publicly traded and the investor held an interest of 5% or less in the mutual fund or ETF at all times during the year preceding the sale or (b) the mutual fund is a domestically controlled qualified investment entity.

• Generally, gain on disposition of an interest in a USRPHC is excluded from the definition of effectively connected earnings and profits.

• A USRPI includes an interest in a US Real Property Holding Company (USRPHC) which generally is defined as a US company whose assets, measured by fair market value, consist of 50% or more of USRPIs at any time during a five-year period.

More Definitions of USRPHC

USRPHC shall have the meaning specified in Section 4.32 of this Agreement.

USRPHC has the meaning set forth in Section 1.1(d) of this Agreement.

USRPHC has the meaning set forth in Section 2.8(i).

USRPHC has the meaning set forth in Section 6.05.

USRPHC has the meaning specified in Section 4.8(d).

USRPHC shall have the meaning ascribed to such term by Section 5.2.

USRPHC has the meaning given such term in Section 3.26(w) of this Agreement.