PFIC Status definition

PFIC Status the Issuer was not a "passive foreign investment company" ("PFIC") as defined in Section 1297 of the United States Internal Revenue Code of 1986, as amended, for its most recently completed taxable year and, based on the Issuer's current projected income, assets and activities, the Issuer does not expect to be classified as a PFIC for any subsequent taxable year;
Sample 1

Examples of PFIC Status in a sentence

  • Lapse in PFIC Status or in Ownership Section 1.1295–1T(c)(2) of the temporary regulations clarifies the status of a shareholder’s section 1295 election with respect to a foreign corporation after the foreign corporation ceases to be a PFIC and a QEF, or after the shareholder ceases to be a shareholder of the PFIC.

  • Any gain would generally be taxable in a manner comparable to that discussed under "PFIC Status" at (v) above.

  • Taxation of capital gains Subject to the discussion on "PFIC Status" at (v) below, upon the sale or exchange of a New CAT Share or a New CAT ADS, a US Holder generally will recognise capital gain or loss for US federal income tax purposes in an amount equal to the difference between the amount realized and the adjusted tax basis in the New CAT Share or the New CAT ADS.

  • Taxation of dividends This discussion of the taxation of dividends is subject to the discussion on "PFIC Status" at (v) below.

  • Such gain generally would be taxable in a manner comparable to that discussed under "PFIC Status" at (v) above.

  • PFIC Status of the Company The Company believes that it was not a PFIC before 2022 and it does not anticipate that it will be a PFIC in 2022, but there can be no assurance that the Company will not become a PFIC in 2023.

  • The topology of LG is the usual sheaf topology with a sub–base of sets {[U, HU ]x : x ∈ X},for all open subsets U of X and wide subgroupoids H of G|U .

  • PFIC Status of the Corporation If the Corporation were to constitute a “passive foreign investment company” under the meaning of Section 1297 of the Code (a “PFIC”, as defined below) for any year during a U.S. Holder’s holding period, then certain potentially adverse rules would affect the U.S. federal income tax consequences to a U.S. Holder as a result of the acquisition, ownership and disposition of Common Shares.

  • The Company has no debt securities or preferred stock that is rated by any “nationally recognized statistical rating organization” (as such term is defined in Section 3(a)(62) of the Exchange Act).(xl) PFIC Status.

  • PFIC Status of AurizonThe tax consequences of the Exchange to a particular U.S. Holder will depend on whether Aurizon was a passive foreign investment company (a “PFIC”) during any year in which a U.S. Holder owned Aurizon Shares.

Related to PFIC Status

  • Domain Status clientDeleteProhibited Domain Status: clientRenewProhibited Domain Status: clientTransferProhibited Domain Status: serverUpdateProhibited Registrant ID: 5372808-ERL Registrant Name: EXAMPLE REGISTRANT Registrant Organization: EXAMPLE ORGANIZATION Registrant Street: 000 XXXXXXX XXXXXX Xxxxxxxxxx Xxxx: ANYTOWN Registrant State/Province: AP Registrant Postal Code: A1A1A1 Registrant Country: EX

  • Active status means (i) for employees, the absence of any interruption or termination of service as an employee, (ii) for Directors, that the Director has not been removed from the Board for cause (as determined by the Company’s shareholders), and (iii) for Consultants, the absence of any interruption, expiration, or termination of such person’s consulting or advisory relationship with the Company or any Subsidiary or the occurrence of any termination event as set forth in such person’s Award Agreement. Active Status shall not be considered interrupted (A) for an employee in the case of sick leave, maternity leave, infant care leave, medical emergency leave, military leave, or any other leave of absence properly taken in accordance with the policies of the Company or any applicable Subsidiary as may be in effect from time to time, and (B) for a Consultant, in the case of any temporary interruption in such person’s availability to provide services to the Company or any Subsidiary which has been granted in writing by an authorized officer of the Company. Whenever a mandatory severance period applies under applicable law with respect to a termination of service as an employee, Active Status shall be considered terminated upon such Employee’s receipt of notice of termination in whatever form prescribed by applicable law.

  • B-BBEE status level of contributor” means the B-BBEE status of an entity in terms of a code of good practice on black economic empowerment, issued in terms of section 9(1) of the Broad- Based Black Economic Empowerment Act;

  • refugee status means the recognition by a Member State of a third-country national or a stateless person as a refugee;

  • Inactive status means the status of a practitioner licensed or registered pursuant to Iowa Code chapter 153 who is not currently engaged in the practice of dentistry, dental hygiene, or dental assisting in the state of Iowa and who has paid the required renewal fee but who has not met the requirements for continuing education.

  • Change in Status means any of the events described below, as well as any other events included under subsequent changes to Code section 125 or regulations issued thereunder, which the Plan Administrator, in its sole discretion and on a uniform and consistent basis, determines are permitted under IRS regulations and under this Plan:

  • Taxable Event means any change in control or other event which triggers the imposition of any Excise Tax on any Payment.

  • Deemed status means acceptance of certification or licensure of a program or service by another certifying body in place of certification based on review and evaluation.

  • Level VI Status exists at any date if, on such date, the Borrower has not qualified for Level I Status, Level II Status, Level III Status, Level IV Status or Level V Status.

  • PFIC means a passive foreign investment company as defined in the Code.

  • Level I Status exists at any date if, as of the last day of the fiscal quarter of the Borrower referred to in the most recent Financials, the Leverage Ratio is less than 1.00 to 1.00.

  • Is regarded as having an impairment means (i) has a physical or mental impairment that does not substantially limit major life activities but that is treated as constituting such a limitation; (ii) has a physical or mental impairment that substantially limits major life activities because of the attitudes of others; or (iii) has none of the impairments defined in paragraph a. of this subdivision but is treated as having such an impairment.

  • Level IV Status exists at any date if, on such date, (i) the Borrower has not qualified for Level I Status, Level II Status or Level III Status and (ii) the Borrower's Xxxxx'x Rating is Baa3 or better or the Borrower's S&P Rating is BBB- or better.

  • REIT Status means, with respect to any Person, (a) the qualification of such Person as a real estate investment trust under the provisions of Sections 856 et seq. of the Code and (b) the applicability to such Person and its shareholders of the method of taxation provided for in Sections 857 et seq. of the Code.

  • proof of B-BBEE status level of contributor means:B-BBEE Status level certificate issued by an authorized body or person;A sworn affidavit as prescribed by the B-BBEE Codes of Good Practice;Any other requirement prescribed in terms of the B-BBEE Act;

  • travel status with respect to an employee means absence of the employee from his/her headquarters or geographic location on Justice Institute of British Columbia business with the approval of the Employer, but travel status does not apply to employees temporarily assigned to a position outside of his/her headquarters or geographic location or to field status employees;

  • Level II Status exists at any date if, on such date, (i) the Borrower has not qualified for Level I Status and (ii) the Borrower's Xxxxx'x Rating is Baa1 or better or the Borrower's S&P Rating is BBB+ or better.

  • Level V Status exists at any date if, on such date, the Borrower has not qualified for Level I Status, Level II Status, Level III Status or Level IV Status.

  • Level III Status exists at any date if, on such date, (i) the Borrower has not qualified for Level I Status or Level II Status and (ii) the Borrower's Xxxxx'x Rating is Baa2 or better or the Borrower's S&P Rating is BBB or better.

  • Tax-Free Status means the qualification of a Distribution or any other transaction contemplated by the IRS Ruling or any Tax Opinion as a transaction in which gain or loss is not recognized, in whole or in part, and no amount is included in income, including by reason of Distribution Taxes, for U.S. federal, state, and local income tax purposes (other than intercompany items, excess loss accounts or other items required to be taken into account pursuant to Treasury Regulations promulgated under Section 1502 of the Code).

  • Individual Resource Status Single Dwelling Contributing Total: 1

  • Probationary status means the 12-month period following

  • Health status-related factor means any of the following factors:

  • Controlled Group Liability means any and all liabilities (i) under Title IV of ERISA, (ii) under Section 302 of ERISA, (iii) under Sections 412 and 4971 of the Code, (iv) as a result of a failure to comply with the continuation coverage requirements of Section 601 et seq. of ERISA and Section 4980B of the Code, and (v) under corresponding or similar provisions of foreign laws or regulations.

  • B-BBEE status level of contributor means the B-BBEE status of an entity in terms of a code of good practice on black economic empowerment, issued in terms of section 9(1) of the Broad-Based Black Economic Empowerment Act;

  • Other health impairment means having limited strength, vitality, or alertness, including a heightened alertness to environmental stimuli, that results in limited alertness with respect to the educational environment, that: