Certain Tax Considerations. (i) Dealer makes the following representations to Company: it is a “foreign person” (as that term is used in section 1.6041-4(a)(4) of the United States Treasury Regulations) for United States federal income tax purposes and a “non-U.S. branch of a foreign person” (as that term is used in section 1.1441-4(a)(3)(ii) of the United States Treasury Regulations) for United States federal income tax purposes.
Appears in 6 contracts
Samples: Letter Agreement (Atlas Air Worldwide Holdings Inc), Letter Agreement (Atlas Air Worldwide Holdings Inc), Letter Agreement (Atlas Air Worldwide Holdings Inc)
Certain Tax Considerations. (i) Dealer makes the following representations to Company: it is a “foreign person” (as that term is used in section 1.6041-4(a)(4) of the United States Treasury Regulations) for United States federal income tax purposes and a “non-U.S. branch each payment received or to be received by it in connection with this Confirmation is effectively connected with its conduct of a foreign person” (as that term is used trade or business in section 1.1441-4(a)(3)(ii) of the United States Treasury Regulations) for United States federal income tax purposesStates.
Appears in 3 contracts
Samples: Letter Agreement (Atlas Air Worldwide Holdings Inc), Letter Agreement (Atlas Air Worldwide Holdings Inc), Kbr, Inc.
Certain Tax Considerations. (i) Dealer makes the following representations represents to Company: Counterparty that it is a “foreign person” (as that term is used in section 1.6041-4(a)(4) of the United States Treasury Regulations) for United States federal income tax purposes and a “non-U.S. branch of a foreign person” (as that term is used in section 1.1441-4(a)(3)(ii) of the United States Treasury Regulations) for United States federal income tax purposes.
Appears in 2 contracts
Samples: Chart Industries Inc, Chart Industries Inc
Certain Tax Considerations. (i) Dealer makes the following representations represents to Company: Company that it is a “foreign person” (as that term is used in section 1.6041-4(a)(4) of the United States Treasury Regulations) for United States federal income tax purposes and a “non-U.S. branch of a foreign person” (as that term is used in section 1.1441-4(a)(3)(ii) of the United States Treasury Regulations) for United States federal income tax purposes.
Appears in 2 contracts
Samples: Letter Agreement (Chart Industries Inc), Chart Industries Inc