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 Section.

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.

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.

  • ACH Rules means the NACHA Operating Rules and NACHA Operating Guidelines, as in effect from time to time.

  • FSA Rules meanss the rules, guidance, principles and codes comprised in the Handbook of Rules and Guidance issued by the FSA. The parties understand and agree that such categorisation is not intended to, and does not, affect the relationship between and among the parties under the 1940 Act or the Advisers Act.

  • M&A Rules means the Provisions on Merging and Acquiring Domestic Enterprises by Foreign Investors, which was promulgated by six Governmental Agencies, namely, the Ministry of Commerce, the State-owned Assets Supervision and Administration Commission, the State Administration for Taxation, the State Administration for Industry and Commerce, the China Securities Regulatory Commission (the “CSRC”), and the State Administration of Foreign Exchange, on August 8, 2006 and became effective on September 8, 2006, as amended by the Ministry of Commerce on June 22, 2009.

  • ICC Rules means the Rules of Arbitration of the International Chamber of Commerce in effect on the date the applicable arbitration proceeding begins.

  • FCC Rules means the rules, regulations, orders and promulgated and published policy statements of the FCC.

  • PPB Rules means the rules of the Procurement Policy Board as set forth in Title 9 of the Rules of the City of New York (“RCNY”), § 1-01 et seq.

  • Criminal Procedure Act means the Criminal Procedure Act, 1977 (Act No. 51 of 1977);

  • House Rules means written and posted rules governing house activities in the AFH-DD. These rules may not conflict with the AFH Bill of Rights.

  • Applicable Laws/ Rules means the laws/ Rules of Islamic Republic of Pakistan/Punjab, as they may be issued and enforced from time to time.

  • Model Rules means the State of Oregon’s Attorney General’s model rules of procedure for Public Contracting, which are set forth in OAR Chapter 137, divisions 46, 47, 48, and 49, and required under ORS 279A.065.

  • Risk Retention Rules means the joint final rule that was promulgated to implement the Risk Retention Requirements (which such joint final rule has been codified, inter alia, at 17 C.F.R. § 246), as such rule may be amended from time to time, and subject to such clarification and interpretation as have been provided by the Office of the Comptroller of the Currency, the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, the Federal Housing Finance Agency, the Commission and the Department of Housing and Urban Development in the adopting release (79 Fed. Reg. 77601 et seq.) or by the staff of any such agency, or as may be provided by any such agency or its staff from time to time, in each case, as effective from time to time as of the applicable compliance date specified therein.

  • Arbitration Rules means the AAA’s Commercial Arbitration Rules and Mediation Procedures.

  • U.S. Risk Retention Rules means the federal interagency credit risk retention rules, codified at 17 C.F.R. Part 246.

  • AIM Rules means the rules published by the London Stock Exchange governing admission to AIM and the regulation of AIM companies as amended or re-issued from time to time;

  • Organic rules means the public organic record and private organic rules of an entity.

  • CCASS Rules means the General Rules of CCASS and the CCASS Operational Procedures in effect from time to time;

  • General Data Protection Regulation GDPR" means regulation (EU) 2016/679 of the European parliament and of the council as amended from time to time.

  • PRA Rules means the Rules included within the PRA handbook issued by the PRA.

  • Mediation Rules As defined in Section 2.03(h)(i).

  • UNCITRAL Arbitration Rules means the arbitration rules of the United Nations Commission on International Trade Law.

  • Benchmarks Regulation means Regulation (EU) 2016/1011 of the European Parliament and of the Council of 8 June 2016 on indices used as benchmarks in financial instruments and financial contracts or to measure the performance of investment funds and amending Directives 2008/48/EC and 2014/17/EU and Regulation (EU) No 596/2014;