Examples of PFIC Rules in a sentence
Lessee's Equipment means any and all fixtures and fittings and other equipment installed in or brought on to or kept on the Leased Premises by the Lessee.
Effects of PFIC Rules on the Domestication Section 1291(f) of the Code requires that, to the extent provided in Treasury Regulations, a U.S. person who disposes of stock of a PFIC recognizes gain notwithstanding any other provision of the Code.
Taxation of U.S. Tax-Exempt Shareholders Passive Foreign Investment Company ("PFIC") Rules - In General.
Applicability Dates Relating to the General PFIC Rules These regulations are proposed to apply to taxable years of United States persons that are shareholders in certain foreign corporations beginning on or after the date of filing of the Treasury Decision adopting these rules as final regulations in the Federal Register.
PFIC Rules Certain adverse U.S. tax consequences apply to a U.S. shareholder in a company that is classified as a passive foreign investment company, which is referred to herein as a PFIC.
The impact of the Passive Foreign Investment Company (PFIC) Rules For U.S. tax purposes, a U.S. passive foreign investment company (PFIC) is a non-U.S. corporation that has at least 75% of its gross income from passive income or holds at least 50% of its average fair market value in assets that produce passive income.
In conclusion, we submit that our proposals are administrable, are fair, meet the goal of Congress when it adopted the PFIC rules of delaying tax to U.S. beneficiaries until they receive a distribution, and integrate the operation of the PFIC Rules with Subchapter J.
SPECIFICATION – SECTION A - TREE PRUNING SERVICE PRUNING OF TREES – RESOURCES AND STANDARDS Pruning of trees shall consist of the following classes of pruning as developed and referenced by the following resources:- Tree Care Industry Association and follow the current American National Standard for Pruning of ANSI A300 Series of Standards for Tree Care Maintenance Operations.
Other PFIC Rules Under Section 1291(f) of the Code, the IRS has issued proposed Treasury Regulations that, subject to certain exceptions, would cause a U.S. Holder that had not made a timely QEF Election to recognize gain (but not loss) upon certain transfers of Common Shares that would otherwise be tax-deferred (e.g., gifts and exchanges pursuant to corporate reorganizations).
It should be noted, however, that in order for an investor to make a QEF elec- tion, the hedge fund must agree to make certain information available to the investor,244 which not all hedge funds are willing to do.c. The PFIC on a PFIC Rules.