USRPI definition

USRPI means “United States real property interest” as defined in Section 897(c)(1) of the Code, and Treasury Regulation Section 1.897-1(c).

USRPI means United States real property interest, as defined in the Code; and

USRPI has the meaning set forth in Section 4.6(c).

Examples of USRPI in a sentence

• Subject to the exception that may apply if our common shares were regularly traded on an established securities market (as described above), if our shares are a USRPI, gain from the sale of our shares would be ECI to the non-U.S. shareholder unless such non-U.S. shareholder were a qualified shareholder or qualified foreign pension fund, each as described below.

• Loans secured by real property located in the United States that do not provide the lender with a participation in profits, gains, appreciation (or similar arrangements) of the real property are generally not treated as USRPIs.In addition, stock of a domestic corporation (including a REIT such as us) will be a USRPI if at least 50% of its real property assets and assets used in a trade or business are USRPIs at any time during a prescribed testing period.

• We currently are not publicly traded and such rules will not apply unless and until our common shares become “regularly traded” on an established securities exchange in the future.Dispositions of Our Common SharesA sale of our common shares by a non-U.S. shareholder generally will not be subject to U.S. federal income tax unless our shares are a USRPI.

• If our shares are not a USRPI, gain from the sale of our shares would not be subject to U.S. federal income tax.

• Even in the event our common shares are not a USRPI, we may choose to withhold on the entire amount of any distribution at the same rate as we would withhold on a dividend because we may not be able to determine at the time we make a distribution whether or not the distribution will exceed our current and accumulated earnings and profits.

More Definitions of USRPI

USRPI. ’ means a U.S. real property interest as defined under Section 897(c) of the Internal Revenue Code.

USRPI means US real property interests;

USRPI shall have the meaning set forth in Section 3.2(f). “VAT” means, in relation to any jurisdiction within the European Community, the value added tax provided for in Directive 2006/112/EC and charged under the provisions of any national legislation implementing that directive or Directive 77/388/EEC together with legislation supplemental thereto and, in relation to any other jurisdiction, the equivalent Tax (if any) in that jurisdiction. “WARN Act” shall have the meaning set forth in Section 4.14. “Welfare Plan” shall have the meaning set forth in Section 4.15(a).

USRPI shall have the meaning set forth in Section 3.2(f).

USRPI means U.S. Restaurant Properties, Inc., a Maryland corporation, the sole owner of General Partner.

USRPI has the meaning ascribed thereto in Section 4.11.

USRPI has the meaning set forth in Section 897(c) and Section 897(g) of the Code.