Recalcitrant definition
Examples of Recalcitrant in a sentence
As part of Standard Bank Plc’s obligations in regard to United States’ (US) Foreign Account Tax Compliance Act (FATCA), financial institutions and Standard Bank Plc s, including STANDARD BANK PLC are required to obtain the Customer’s tax related information to determine whether the Customer’s account is a US Account, account held by a Recalcitrant Account holder, or Non- Participating Financial Institution or Standard Bank Plc.
The FATCA regime is now in effect for payments from sources within the United States and will apply to certain "foreign passthru payments" made from a Participating FFI to a Recalcitrant Holder or a nonparticipating FFI no earlier than 1 January 2019 (or the date of publication of the final regulations defining “foreign passthru payment” for FATCA purposes).
If I am identified as a Recalcitrant Customer under FATCA, GTN Asia reserves the right to and terminate this Agreement and close my Account/s.
Accordingly, the Fiduciary and financial institutions through which payments on the Notes are made may be required to withhold FATCA Withholding if (i) any FFI through or to which payment on such Notes is made is not a Participating FFI, a Reporting FI, or otherwise exempt from or in deemed compliance with FATCA or (ii) an investor is a Recalcitrant Holder.
Accordingly, the Issuer, the Guarantor, or any other financial institution through which payments on the Bonds are made, may be required to withhold FATCA Withholding on such payments to a nonparticipating FFI or a Recalcitrant Holder.
Further, an FFI in a Model 1 IGA jurisdiction would not be required to withhold under FATCA or an IGA (or any law implementing an IGA or agreement with the IRS relating to FATCA) (any such withholding being a “FATCA Withholding”) from payments it makes (unless, in certain limited circumstances, where the payments are made to a Recalcitrant Holder).
I understand that according to FATCA, GTN Asia is required to submit my account details and any other Personal Information to the Internal Revenue Service of the United States of America (IRS), MAS, Inland Revenue Authority of Singapore (IRAS), any other regulators or third parties as per applicable statutory requirements from time to time if my account falls under the category of a Reportable “U.S. Account” or “Recalcitrant Customer / Recalcitrant Account Holder” under FATCA.
FATCA implementation is being phased in from 01 July 2014 for payments from sources within the United States and is currently proposed to apply to "foreign passthru payments" (a term not yet defined) made by an FFI to a non-participating FFI or Recalcitrant Holder no earlier than 01 January 2017.
The Partnership might find itself in a position to close out any NPFFI or Recalcitrant Holder (by for example, forcing it to sell its Limited Partnership Units) in order to comply with its obligations under IGA Model 1 and avoid U.S. withholding tax.
Recalcitrant organic carbon that forms during the production of biochar by pyrolysis is resistant to decomposition by soil microorganisms, allowing the carbon to remain sequestered from the atmosphere for hundreds to thousands of years.