Examples of US Holders in a sentence
For corporate U.S. Holders, capital losses may only be used to offset capital gains.
For corporate U.S. Holders, losses from the sale or exchange of capital assets may only be used to offset capital gains.
U.S. Holders (as defined in “Tax Considerations - Certain U.S. Federal Income Tax Considerations”) may be able to avoid these adverse consequences by filing a “protective” qualified electing fund election with respect to their Class E Notes and Class F Notes.
Alternatively, if the Class E Notes or Class F Notes are treated as equity for U.S. federal income tax purposes, U.S. Holders of those Notes could be subject to the rules pertaining to 10 per cent.
U.S. Holders of Claims should consult their own tax advisors regarding the proper allocation of the consideration received by them under the Plan.