Certain Tax Considerations. (i) Dealer makes the following representations to Counterparty: 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 5 contracts
Samples: Atlas Air Worldwide Holdings Inc, Atlas Air Worldwide Holdings Inc, Atlas Air Worldwide Holdings Inc
Certain Tax Considerations. (i) Dealer makes the following representations to Counterparty: 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: Kbr, Inc., Atlas Air Worldwide Holdings Inc, Atlas Air Worldwide Holdings Inc