Fiscally Transparent Entity definition
Fiscally Transparent Entity means an entity or arrangement that has not provided an Investor Self-Declaration on its own behalf because, under applicable tax treaties or the domestic law of the Source Country, the partners, beneficiaries or similar persons are treated for tax purposes as the owners of the income received by the entity or arrangement;
Fiscally Transparent Entity means a Person or arrangement that is classified or treated, for U.S. federal income tax purposes, as a partnership, a “disregarded entity” (within the meaning of Treasury Regulations Section 301.7701-2), an S corporation (within the meaning of Section 1361(a)(1) of the Code) or a qualified subchapter S subsidiary (within the meaning of Section 1361(b)(3) of the Code).
Fiscally Transparent Entity means an entity or arrangement with respect to which, under applicable tax treaties or the domestic law of the Source Country, the partners, beneficiaries or similar persons are treated for tax purposes as the owners of the income received by the entity or arrangement;
More Definitions of Fiscally Transparent Entity
Fiscally Transparent Entity means an entity whose income, expenditure, profit or loss is treated by the laws of a territory as if it were derived or incurred by the direct owner of that entity in proportion to its interest in that entity;
Fiscally Transparent Entity means an entity or arrangement that has not provided an Investor Self-Declaration on its own behalf because, with respect to Covered Payments its partners, beneficiaries or similar persons are treated as deriving the payments directly;