Examples of Non-Electing Shareholder in a sentence
In addition, a holder who does not tender an Election for all of his or her shares will be deemed to be a Non-Electing Shareholder with respect to those shares not tendered.
However, if the mark-to-market election is made by a Non-Electing Shareholder after the beginning of the holding period for the PFIC stock, then the Section 1291 rules may still apply to certain dispositions (or deemed dispositions) of, distributions on and other amounts taxable with respect to its Common Stock.
Treat the threads of all fasteners with anti-seize compound before installing. Ensure that all pins are present and properly installed (including hairpin cotter pins where applicable).
Each unit consists of one common share and a half share purchase warrant.
Mr. YOUNG, I want to commend you and Mr. LOBIONDO, the distinguished gentleman from New Jersey, for having chaired the full committee and the Coast Guard subcommittee, along with your respective ranking members, Mr. OBERSTAR, the gentleman from Min- nesota; and Mr. FILNER, the gentleman from California.
If the PFIC-for-PFIC Exception is available, non-recognition treatment depends on the Non-Electing Shareholder satisfying certain requirements described in the Proposed Regulations.
Holders of ICNB Financial Corporation common stock whose Election Form and certificate(s) are not so received or who revoke their Election Form will be considered a Non-Electing Shareholder.
If (a) the Company and its Subsidiaries are or have been PFICS and (b) contrary to expectations, the Arrangement is treated as a taxable transaction for U.S. federal income tax purposes, then the U.S. federal income tax consequences of the Arrangement to a Non-Electing Shareholder will generally be as described above under the heading “Treatment of the Arrangement as a Taxable Transaction”, except that any gain recognized will be subject to tax under the excess distribution regime described above.
Non-Electing Shareholders The Proposed Regulations provide that a Non-Electing Shareholder is required to recognize all of the Non-Electing Shareholder’s gain on a disposition of PFIC shares in a transaction that qualifies as a Reorganization unless the Non-Electing Shareholder receives in the exchange shares of another corporation that is classified as a PFIC for the taxable year that includes the day after the Effective Date (the “ PFIC-for-PFIC Exception”).
Holders of GGP shares who do not properly and timely make an election as provided in the preceding sentences, who properly and timely revoke a prior election without properly making a subsequent election or who fail to make a valid election for any reason will each be considered a Non-Electing Shareholder.