Form 5471 definition

Form 5471 means the Form, as adopted by the IRS, entitled "Information Return of U.S. Persons With Respect to Certain Foreign Corporations" or any similar, successor Form as adopted by the IRS.
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Form 5471 is defined in Section 2.02(c).
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Form 5471 means the Form, as adopted by the IRS, entitled “Information Return of U.S. Persons With Respect to Certain Foreign Corporations” or any similar, successor Form as adopted by the IRS. “Form 8621” shall mean the Form, as adopted by the IRS, entitled “Return of a Shareholder of a Passive Foreign Investment Company or Qualified Electing Fund” or any similar, successor Form as adopted by the IRS. “Governmental Authority” shall mean any (a) national, federal, state, local, county, municipal, city, town, village, district, foreign, or other government or jurisdiction of any kind, character, or nature whatsoever, (b) governmental or quasi-governmental authority of any kind, character, or nature whatsoever (including, without limitation, any court, judge, tribunal, agency, branch, department, commission, board, bureau, official, administrator, regulator, legislator, instrumentality, arbitrator, or mediator), (c) multi-national organization or body, or (d) individual Person or body exercising, or entitled to exercise, any administrative, executive, judicial, legislative, police, regulatory, or taxing authority or power of any kind, character, or nature whatsoever. “Group” shall have the meaning assigned to such term in Section 13(d)(3) of the Securities Act. “Involuntary Basis” shall mean any act or omission after the date hereof which causes SOF to become a United States Shareholder other than by reason of the purchase or other voluntary acquisition of Shares by SOF or any of its Affiliates. “IRS” shall mean the United States Internal Revenue Service. “Legal Requirement” shall mean, with respect to any Person, any federal, state, local, municipal, foreign, international, multinational, or other administrative order, constitution, law, ordinance, principle of common law, regulation, statute, or treaty applicable to such Person. “Libor Rate” shall mean, the average daily rate of a fluctuating rate of interest equal to the three (3) month London interbank offered rate as published in the “Money Rates” section of The Wall Street Journal. “Notification” shall mean a writing containing any information required by this Shareholders’ Agreement to be communicated to any Person, which shall be sent in accordance with Section 9.2 hereof. “Order” shall mean any award, decision, injunction, judgment, order, ruling, subpoena, or verdict entered, issued, made, or rendered by any court, administrative agency, or other Governmental Authority or by any arbitrator. “Organizational D...
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Examples of Form 5471 in a sentence

  • It is expected, however, that these issues will be alleviated in practice through the conclusion of IGAs. Comments also requested that the rules defining withholdable payment exclude payments that are reported by the withholding agent on Form 5471 or 5472 in order to alleviate duplicative reporting.

  • Thus, the classification of a foreign entity is relevant, for example, on the date that an interest in the entity is acquired which will require a U.S. person to file an information return on Form 5471.

  • In the case of a controlled foreign cor- poration (CFC), as defined in section 957, that has fast-pay stock out- standing at any time during its taxable year (during which time it was a CFC), each controlling United States share- holder (within the meaning of § 1.964– 1(c)(5)) must attach the statement de- scribed in paragraph (f)(2) of this sec- tion to the shareholder’s Form 5471 for the CFC’s taxable year.

  • Also, include country of incorporation or formation, if applicable.(b) Description of each class of stock held by shareholder.Note: This description should match the corresponding description entered in Schedule A, column (a).(c) Number of shares held atbeginning of annual accounting period(d) Number of shares held at end of annualaccounting period Form 5471 (Rev.

  • The instructions to Form 5471 clearly state that the only mechanism for submitting the form is attaching it to an income tax return.

  • Another comment suggested that the IRS could amend Schedule E on Form 5471 to include this type of information about the changes to prior year U.S. tax liabilities that result from foreign tax redeterminations.

  • On June 1, 2008, the Director of Field Operations mailed a notice to A of A’s failure to file Form 5471 for 2007 with respect to FC.

  • On April 15, 2008, A timely filed its 2007 income tax return but did not file Form 5471 with respect to FC’s 2007 annual accounting period.

  • To support the amount of subpart F income claimed, all federal forms, schedules and worksheets associated with I.R.S. Form 5471 must be attached to the Form F-1120.

  • Either Form 5471 or Form 2952 if such taxable year ends on or after De- cember 31, 1982 and before December 31, 1963.

Related to Form 5471

  • IRS means the United States Internal Revenue Service.

  • Section 338 Forms has the meaning set forth in Section 6.5(d).

  • Income Tax Returns mean all Tax Returns that relate to Income Taxes.

  • Income Tax Return means any return, declaration, report, claim for refund, or information return or statement relating to Income Taxes, including any schedule or attachment thereto, and including any amendment thereof.

  • Tax Return means any return, declaration, report, claim for refund, or information return or statement relating to Taxes, including any schedule or attachment thereto, and including any amendment thereof.

  • Tax return preparer means any individual described in Section 7701(a)(36) of the Internal Revenue Code and 26 C.F.R. 301.7701-15 .

  • Internal Revenue Service or “IRS” means the U.S. Internal Revenue Service or any successor thereto.

  • Tax Certification Forms means any forms or other documentation as may be issued or required by a Tax Authority or by the Bank from time to time to confirm the tax status of the Customer or of a Connected Person.

  • Non-Income Tax Return means any Tax Return relating to any Tax other than an Income Tax.

  • Form W-8ECI means Form W-8ECI (Certificate of Foreign Person’s Claim for Exemption from Withholding of Tax on Income Effectively Connected with the Conduct of a Trade or Business in the United States) of the Department of the Treasury of the United States of America, and any successor form.

  • Federal Tax Certificate means the Issuer's Federal Tax Certificate dated as of the Issue Date, as the same may be amended or supplemented in accordance with the provisions thereof.

  • Tax Authorities means Hong Kong or foreign tax, revenue or monetary authorities.

  • United States Tax Compliance Certificate has the meaning specified in Section 3.01.

  • File “Filed,” or “Filing” means file, filed, or filing with the Bankruptcy Court or its authorized designee in the Chapter 11 Cases.

  • Consolidated federal income tax return means a consolidated return filed for federal income tax purposes pursuant to section 1501 of the Internal Revenue Code.

  • Reports means the reports described in Schedule B as well as any other reports or information required to be provided under the Enabling Legislation or this Agreement;

  • Rule 482 Statement means a document that contains the number of Securities issued, the offering price and any other items dependent upon the offering price, prepared in accordance with the provisions of Rule 482 of the 1933 Act, a copy of which shall be attached as Schedule D hereto. “Statutory Prospectus” as of any time means the prospectus relating to the Securities that is included in the Registration Statement immediately prior to that time, including any document incorporated by reference therein. Each preliminary prospectus and the prospectus filed as part of the effective Registration Statement or as part of any amendment thereto, or filed pursuant to Rule 497 under the 1933 Act, complied when so filed in all material respects with the Rules and Regulations and each preliminary prospectus and the Prospectus delivered to the Underwriters for use in connection with this offering was identical to the electronically transmitted copies thereof filed with the Commission pursuant to XXXXX, except to the extent permitted by Regulation S-T. If a Rule 462(b) Registration Statement is required in connection with the offering and sale of the Securities, the Fund has complied or will comply with the requirements of Rule 111 under the 1933 Act Rules and Regulations and Rule 3a of the Commission’s Internal and Other Procedures (“Rule 3a”) relating to the payment of filing fees thereof. The Fund, subject to the Registration Statement having been declared effective and the filing of the Prospectus under Rule 497, has taken all required action under the 1933 Act, the 1940 Act, the Securities and Exchange Act of 1934, as amended (the “1934 Act”) and the Rules and Regulations to make the public offering and consummate the sale of the Securities as contemplated by this Agreement.

  • Tax Package has the meaning assigned in Section 6.01(b);

  • Tax Returns The federal income tax return on Internal Revenue Service Form 1066, U.S. Real Estate Mortgage Investment Conduit Income Tax Return, including Schedule Q thereto, Quarterly Notice to Residual Interest Holders of the REMIC Taxable Income or Net Loss Allocation, or any successor forms, to be filed by the Trustee on behalf of each REMIC, together with any and all other information reports or returns that may be required to be furnished to the Certificateholders or filed with the Internal Revenue Service or any other governmental taxing authority under any applicable provisions of federal, state or local tax laws.

  • Form W-8BEN means Form W-8BEN (Certificate of Foreign Status of Beneficial Owner for United States Tax Withholding) of the Department of Treasury of the United States of America, and any successor form.

  • Filed means hand delivered to the Commission's office in Richmond or any regional office

  • Section 336(e) Election has the meaning set forth in Section 7.06.

  • Tax or “Taxes” means any federal, state, local or foreign income, gross receipts, property, sales, use, license, excise, franchise, employment, payroll, withholding, alternative or add on minimum, ad valorem, transfer or excise tax, or any other tax, custom, duty, governmental fee or other like assessment or charge of any kind whatsoever, together with any interest or penalty, imposed by any Governmental Entity.

  • Local health department means the same as that term is defined in Section 26A-1-102.