Form 8621 definition

Form 8621 means the Form, as adopted by the IRS, entitled "Return of a Shareholder of a Passive Foreign Investment Company or Qualified Electing Fund" or any similar, successor Form as adopted by the IRS.
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Form 8621 means the Form, as adopted by the IRS entitled, “Return of a Shareholder of a Passive Foreign Investment Company or Qualified Electing Fund” or any similar, successor Form as adopted by the IRS.
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Form 8621 means the Form, as adopted by the IRS, entitled “Return of a Shareholder of a Passive Foreign Investment Company or Qualified Electing Fund” or any similar, successor Form as adopted by the IRS. “Governmental Authority” shall mean any (a) national, federal, state, local, county, municipal, city, town, village, district, foreign, or other government or jurisdiction of any kind, character, or nature whatsoever, (b) governmental or quasi-governmental authority of any kind, character, or nature whatsoever (including, without limitation, any court, judge, tribunal, agency, branch, department, commission, board, bureau, official, administrator, regulator, legislator, instrumentality, arbitrator, or mediator), (c) multi-national organization or body, or (d) individual Person or body exercising, or entitled to exercise, any administrative, executive, judicial, legislative, police, regulatory, or taxing authority or power of any kind, character, or nature whatsoever. “Group” shall have the meaning assigned to such term in Section 13(d)(3) of the Securities Act. “Involuntary Basis” shall mean any act or omission after the date hereof which causes SOF to become a United States Shareholder other than by reason of the purchase or other voluntary acquisition of Shares by SOF or any of its Affiliates. “IRS” shall mean the United States Internal Revenue Service. “Legal Requirement” shall mean, with respect to any Person, any federal, state, local, municipal, foreign, international, multinational, or other administrative order, constitution, law, ordinance, principle of common law, regulation, statute, or treaty applicable to such Person. “Libor Rate” shall mean, the average daily rate of a fluctuating rate of interest equal to the three (3) month London interbank offered rate as published in the “Money Rates” section of The Wall Street Journal. “Notification” shall mean a writing containing any information required by this Shareholders’ Agreement to be communicated to any Person, which shall be sent in accordance with Section 9.2 hereof. “Order” shall mean any award, decision, injunction, judgment, order, ruling, subpoena, or verdict entered, issued, made, or rendered by any court, administrative agency, or other Governmental Authority or by any arbitrator. “Organizational Documents” shall mean (a) the articles or certificate of incorporation, memorandum of association and the bye-laws of a corporation; (b) the partnership agreement or Appendix A to Amended and Restated S...
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Examples of Form 8621 in a sentence

  • The Company has prepared, or caused to be prepared, and has submitted for review to the Purchaser on or prior to the date hereof, Internal Revenue Service Form 8621 and such amended United States Federal income Tax Returns (and other documentation), as required for the Company to make a retroactive "Qualified Electing Fund" election, pursuant to Treasury Regulations Section 1.1295-3T(f), effective for the Company's entire holding period, with respect to the Company's interest in Omnitel.

  • Upon the presentation of a completed Form 8621 to SOF by the Accounting Firm for any taxable year for filing with the IRS as provided in Section 4.1(e) above, the Company shall further certify that the Form 8621 is correct and complete.

  • The Tax Package shall include fully completed information reports required to be included with any Remainco Consolidated Return, any Remainco-New News Corporation Combined Return, and any Remainco Separate Return, including without limitation IRS Form 5471, Form 8621, Form 926 and any statements required to be attached to the applicable Tax Return, to the extent such reports relate to items of a member of the New News Corporation Group.

  • Such distribution shall be made by no later than sixty (60) days following the filing by SOF with the IRS of the Form 8621 reporting the additional taxes or includible amount.

  • U.S. Holders should consult their own tax advisors regarding the requirements of filing such information returns under these rules, including the requirement to file an IRS Form 8621 annually.

  • If any additional amount of tax is later determined to be owed as a result of a challenge by the IRS as contemplated by Section 4.1(f) above or as a result of an amendment to the Form 8621 for any reason at the request or recommendation of the Accounting Firm, the Company shall make an additional shareholder distribution hereunder by no later than sixty (60) days following the remittance by SOF to the U.S. Treasury of such additional tax amount.

  • Each insurance policy listed on Section 5.11 of the Company Disclosure Schedule is valid, binding and enforceable by the Company in accordance with its terms, has not been terminated by any party thereto and all premiums due with respect to such insurance policies have been paid.

  • If Real or the Investor Members determine that Real is a PFIC, Real will provide the Investor Members with the information necessary to permit the limited partners of the Investor Members to complete their tax returns as well as United States Internal Revenue Service Form 8621, including information necessary to make and maintain a “qualified electing fund” election within the meaning of Section 1295 of the Code, within 90 days of the close of the taxable year.

  • If you own our ordinary shares during any year in which we are classified as a PFIC, you will generally be required to file an IRS Form 8621 with respect to the company with your federal income tax return for that year.

  • See also the discussion regarding Form 8621, Information Return by a Shareholder of a Passive Foreign Investment Company or Qualified Electing Fund, above.