Examples of U.S. Holder in a sentence
The receipt of cash pursuant to the Acquisition by a US Holder as consideration for the transfer of its Scheme Shares pursuant to the Scheme may be a taxable transaction for US federal income tax purposes and under applicable US state and local, as well as foreign and other, tax laws.
The discussion of reporting requirements set forth above is not intended to constitute a complete description of all reporting requirements that may apply to a U.S. Holder.
Each Allarity A/S shareholder who is a U.S. Holder would recognize gain or loss on the liquidating distribution in an amount equal to the difference between the fair market value of the Delaware Common Stock received in the Recapitalization Share Exchange and such shareholder’s basis in its Allarity A/S stock.
Any U.S. Holder who converts or otherwise disposes of the foreign currency after the date of receipt may have a foreign currency exchange gain or loss that would be treated as ordinary income or loss, and generally will be U.S. source income or loss for foreign tax credit purposes.
A U.S. Holder may have foreign currency gain or loss if the dividend is converted into U.S. dollars after the date of receipt.