foreign person


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However, if the stock had been held by a foreign person who beneficially owned more than 5% of the FMV of that class at any time during the previous five-year period, that interest is a USRP interest if the corporation qualifies as a USRPHC, and the U.
source income paid to foreign persons, although both categories had smaller amounts in 2011 than they did in 2010.
This exemption is justified for foreign corporations owned by foreign persons.
Second, given all of the recent press dealing with the use of derivatives by foreign persons (primarily offshore hedge funds) to convert what would otherwise be U.
Furnishing assistance (including training) to a foreign person, whether in the U.
For example, a foreign person would not be subject to withholding tax to the extent that the rights received are in exchange for the performance of services outside the United States.
39) The Joint Committee also noted that if a foreign person maintains an office or other fixed place of business in the United States, the Act provides an exception to this general rule if the income is attributable to the U.
Even giving the fullest weight to the prescriptions in Art 36, [the court does] not see how it can be contended that they in any way affect the carrying out of an investigation by interrogation of a foreign person coming so this country.
Domestic corporations controlled by foreign persons is a study of corporations that are incorporated in the United States and whose voting stock is 50 percent or more owned by a foreign person.
Nominees that receive quarterly cash distributions from us that are subject to US income tax withholding which are to be paid to (or for the account of) any foreign person directly by such nominees are treated as the US tax withholding agent with respect to our quarterly cash distributions and the obligation to withhold US income tax from such distributions will be imposed solely on such nominees.
Accordingly, if a foreign person sells an interest in a partnership that holds both USRPIs and non-USRPIs, Sec.
Defense companies considering a transaction that could result in a foreign person acquiring control of the business should prepare for close regulatory scrutiny.

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