A U.S. REVOLVER ADVANCES.
A U.S stockholder who is not a dealer in securities generally must treat any gain or loss realized on a taxable disposition of our stock as long-term capital gain or loss if the U.S. stockholder has held such stock for more than one year, and otherwise as short-term capital gain or loss. In general, a U.S. stockholder will realize gain or loss in an amount equal to the difference between (1) the sum of the fair market value of any property and the amount of cash received in such disposition and (2) the U.S. stockholder’s adjusted tax basis in such stock. A U.S. stockholder’s adjusted tax basis in our stock generally will equal the U.S. stockholder’s acquisition cost, increased by the excess of undistributed net capital gains deemed distributed by us to the U.S. stockholder over the federal corporate income tax deemed paid by the U.S. stockholder on such gains and reduced by any returns of capital. However, a U.S. stockholder must treat any loss on a sale or exchange of our stock held by such stockholder for six months or less as a long-term capital loss to the extent of capital gain dividends and any other actual or deemed distributions from us that such U.S. stockholder treats as long-term capital gain. All or a portion of any loss that a U.S. stockholder realizes on a taxable disposition of shares of our stock may be disallowed if the U.S. stockholder purchases other shares of our stock within 30 days before or after the disposition.
A U.S employer includes a corporation organized under the laws of the United States or any state, a partnership if at least two thirds of the partners are U.S. residents, a person who is a resident of the U.S. or a trust if all the trustees are U.S. residents. The term also includes a foreign affiliate of a U.S. employer if the U.S. employer has entered into an agreement with the Internal Revenue Service (IRS) under section 3121(l) of the Internal Revenue Code to pay Social Security taxes for U.S. citizens and residents employed by the affiliate. Certificate of coverage A certificate of coverage issued by one country serves as proof of exemption from Social Security taxes on the same earnings in the other country. Certificates for employees To establish an exemption from compulsory coverage and taxes under the Luxembourg system, your employer must request a certificate of coverage (form USA/LUX 1) from the U.S. at this address: Social Security Administration Office of International Programs P.O. Box 17741 Baltimore, Maryland 21235-7741 USA If preferred, the request may be sent by FAX to (000) 000-0000. Please note this FAX number should only be used to request certificates of coverage. No special form is required to request a certificate but the request must be in writing and provide the following information: • Full name of worker (including maiden name for married woman); • Date and place of birth; • Citizenship; • Country of worker’s permanent residence; • U.S. Social Security number; • Date of hire; • Country of hire; • Name and address of the employer in the U.S. and Luxembourg; and • Date of transfer and anticipated date of return. In addition, your employer must indicate if you remain an employee of the U.S. company while working in Luxembourg or if you become an employee of the U.S. company’s affiliate in Luxembourg. If you become an employee of an affiliate, your employer must indicate if the U.S. company has an agreement with the IRS under section 3121(l) of the Internal Revenue Code to pay U.S. Social Security taxes for U.S. citizens and residents employed by the affiliate and, if yes, the effective date of the agreement. Your employer can also request a certificate of U.S. coverage for you over the Internet using a special online request form available at xxx.xxxxxxxxxxxxxx.xxx/xxx. Only an employer can use the online form to request a certificate of coverage. A self-employed person must submit a request by mail or fax. To establish your exemption ...
A U.S air carrier may not wet lease from a foreign air carrier (see Volume 12, Chapter 3, Section 2).
A U.S employer includes a corporation organized under the laws of the United States or any state, a partnership if at least two thirds of the partners are U.S. residents, a person who is a resident of the U.S. or a trust if all the trustees are U.S. residents. The term also includes a foreign affiliate of a U.S. employer if the U.S. employer has entered into an agreement with the Internal Revenue Service (IRS) under section 3121(l) of the Internal Revenue Code to pay Social Security taxes for U.S. citizens and residents employed by the affiliate. Certificate of coverage A certificate of coverage issued by one country serves as proof of exemption from Social Security taxes on the same earnings in the other country.
