PFIC Rules definition

PFIC Rules means 26 U.S.C. §§ 1291-98 or any similar statutes hereafter enacted having substantially the same purpose and effect as such Code Sections.
View Source
PFIC Rules means 26 U.S.C. §§ 1291-98 or any similar statutes hereafter enacted having substantially the same purpose and effect as such Code Section.
View Source
PFIC Rules means 26 U.S.C. §§ 1291-98 or any similar statutes hereafter enacted having substantially the same purpose and effect as such Code Sections. “Piggyback Notice” shall have the meaning as set forth in Section 6.3. “Preemptive Notice” shall mean a Notification which shall describe fully: (i) the terms, including the price, of the proposed Transfer; (ii) the number of Shares equal to SOF’s Pro Rata Amount of such Shares being sold; (iii) method of proposed Transfer; and (iv) the proposed closing date of the Transfer. “Preemptive Right” shall have the meaning assigned to such term in Section 7.1. “Preemptive Shares” shall have the meaning assigned to such term in Section 7.1. “Proceeding” shall mean any formal action, arbitration, mediation, dispute resolution, audit, hearing, investigation, litigation, or suit (whether civil, criminal, administrative, investigative) in, commenced, brought, conducted, or heard by or before, or otherwise involving, any judge, court, arbitrator, mediator, or Governmental Authority of any kind, character, or nature, the results of which shall be legally binding on the parties subject thereto. “Process Agent” shall have the meaning set forth in Section 9.3. “Prohibited Transferees” has the meaning set forth in Section 9.7. “Pro Rata Amount” shall have the meaning set forth in Section 7.1. “Prospectus” shall mean the prospectus included in a Registration Statement (including, without limitation, a prospectus that includes any information previously omitted from a prospectus filed as part of an effective registration statement in reliance upon Rule 430A promulgated under the Securities Act), as amended or supplemented by any prospectus supplement, with respect to the terms of the offering of any portion of the Registrable Securities covered by a Registration Statement, and all other amendments and supplements to the Prospectus, including post-effective amendments, and all material incorporated by reference or deemed to be incorporated by reference in such Prospectus. “Put Closing” shall have the meaning set forth in Section 6.6. Appendix A to Amended and Restated Shareholders’ Agreement
View Source

Examples of PFIC Rules in a sentence

  • Subject to the discussion under "PFIC Rules," a US Holder that receives a distribution, including a constructive distribution, as described below, with respect to common shares will be required to include the amount of such distribution in gross income as a dividend (without reduction for any Canadian income tax withheld from such distribution) to the extent of our current and accumulated "earnings and profits," as computed for US federal income tax purposes.

  • Subject to the discussion under "PFIC Rules," upon the sale or other taxable disposition of our common shares, a US Holder generally will recognize capital gain or loss in an amount equal to the difference between the US dollar value of cash received plus the fair market value of any property received and such US Holder's tax basis in such common shares sold or otherwise disposed of.

Related to PFIC Rules

  • HKIAC Rules shall have the meaning ascribed to it in Section 10.13(a).

  • HIPAA Rules means the Privacy, Security, Breach Notification, and Enforcement Rules at 45 CFR Part 160 and Part 164.

  • CySEC Rules means the Rules, Directives, Regulations, Guidance notes, opinions or recommendations of CySEC.

  • FCA Rules means the Rules included within the FCA Handbook issued by the FCA.

  • JAMS Rules has the meaning assigned thereto in Section 13 hereof.