QEF Election definition

QEF Election has the meaning set forth in Section 6.7.

QEF Election has the meaning ascribed to such term in Section 3.3(a).

QEF Election has the meaning ascribed to it in Section 8.3 hereof.

Examples of QEF Election in a sentence

• A U.S. Holder that does not make either a QEF Election or a Mark-to-Market Election will be referred to in this summary as a “Non-Electing U.S. Holder.” A Non-Electing U.S. Holder will be subject to the rules of Section 1291 of the Code (described below) with respect to (a) any gain recognized on the sale or other taxable disposition of Common Shares and (b) any “excess distribution” received on the Common Shares.

• A U.S. Holder that makes a timely and effective QEF Election for the first tax year in which the holding period of its Common Shares begins generally will not be subject to the rules of Section 1291 of the Code discussed above with respect to its Common Shares.

• A U.S. shareholder who makes a QEF Election generally must report on a current basis its share of the Corporation’s net capital gain and ordinary earnings for any year in which the Corporation is a PFIC, whether or not the Corporation distributes any amounts to its shareholders.

• If a U.S. Holder that made a QEF Election has an income inclusion, such a U.S. Holder may, subject to certain limitations, elect to defer payment of current U.S. federal income tax on such amounts, subject to an interest charge.

• If we are a PFIC for any tax year during which a US Holder owns our common shares, the US federal income tax consequences to such US Holder of the acquisition, ownership, and disposition of such shares will depend on whether and when such US Holder makes an election to treat us and each Subsidiary PFIC, if any, as a QEF Election under Section 1295 of the Code, or makes a Mark-to-Market Election with respect to our common shares under Section 1296 of the Code.

More Definitions of QEF Election

QEF Election means a “qualified electing fund” election under Section 1295 of the Code.

QEF Election means an election made pursuant to section 1295(b) of the Code to cause the Company to be treated as a “qualified election fund” pursuant, to section 1292 to 1295 of the Code;

QEF Election means “qualified electing fund” as established in Code Section 1295.

QEF Election has the meaning given in clause 5.2;

QEF Election means an election to treat a PFIC as a qualified electing fund for purposes of Section 1295 of the Code and the regulations thereunder.

QEF Election means a “qualified electing fund” election under Section 1295 of the Code. “Sarbanes-Oxley Act” means the Sarbanes-Oxley Act of 2002.

QEF Election shall have the meaning ascribed to it in Section 11.6 of this Agreement.