Sentences with phrase «entity for income tax purposes»

Not exact matches

If an entity or arrangement treated as a partnership for U.S. federal income tax purposes holds shares of our common stock, the tax treatment of a person treated as a partner generally will depend on the status of the partner and the activities of the partnership.

Our post-offering organizational structure will allow the Continuing LLC Owners to retain their equity ownership in Desert Newco, an entity that is classified as a partnership for U.S. federal income tax purposes, in the form of LLC Units.

SSE Holdings will continue to be treated as a partnership for U.S. federal income tax purposes and, as such, will not be subject to any entity - level U.S. federal income tax.

It does not discuss all aspects of U.S. federal income taxation that may be relevant to particular holders in light of their particular circumstances or to holders subject to special rules under the Code (including, but not limited to, insurance companies, tax - exempt organizations, financial institutions, broker - dealers, partners in partnerships (or entities or arrangements treated as partnerships for U.S. federal income tax purposes) that hold HP Co. common stock, pass - through entities (or investors therein), traders in securities who elect to apply a mark - to - market method of accounting, stockholders who hold HP Co. common stock as part of a «hedge,» «straddle,» «conversion,» «synthetic security,» «integrated investment» or «constructive sale transaction,» individuals who receive HP Co. or Hewlett Packard Enterprise common stock upon the exercise of employee stock options or otherwise as compensation, holders who are liable for the alternative minimum tax or any holders who actually or constructively own 5 % or more of HP Co. common stock).

SCH was treated as a partnership for U.S. federal income tax purposes, and as such, was not subject to any U.S. federal entity - level income taxes.

We believe that the Continuing LLC Owners generally find it advantageous to hold their equity interests in an entity that is not taxable as a corporation for U.S. federal income tax purposes.

These entities are now owned 100 % by us or our subsidiaries, and are treated as a consolidated group for federal income tax purposes.

Our post-offering organizational structure will allow the Continuing LLC Owners to retain their equity ownership in Desert Newco, an entity that is classified as a partnership for U.S. federal income tax purposes, in

In all foreign countries except Canada, we operate through legal entities disregarded for U.S. income tax purposes, and are subject to income tax in both the local country and the U.S. Unremitted earnings from our Canadian subsidiary, which are intended to be permanently reinvested outside the U.S., are not material.

Our effective tax rate differs from statutory rates primarily due to our pass - through entity structure for U.S. income tax purposes, while being treated as taxable in certain states and various foreign countries as well as for certain subsidiaries.

In all foreign countries except Canada, we operate through legal entities disregarded for U.S. income tax purposes, and are subject to income tax in both the local country and the U.S. Unremitted earnings from our Canadian subsidiary, which we intend to permanently reinvest outside the U.S., are not material.

The potential tax benefits from investing in MLPs depend on their being treated as partnerships for federal income tax purposes and, if the MLP is deemed to be a corporation, then its income would be subject to federal taxation at the entity level, reducing the amount of cash available for distribution to the fund which could result in a reduction of the fund's value.

A Shareholder that is not a US Shareholder as defined above (other than a partnership, or an entity treated as a partnership for US federal income tax purposes) is generally considered a «Non-US Shareholder» for purposes of this discussion.

Fortunately, there are many ways to acquire tax ownership of property that can involve the use of certain business entities or trusts that are disregarded for federal income tax purposes.

Each fund is treated as a separate entity for federal income tax purposes and is not combined with the Trust's other funds.

Interests in an entity that is considered to be a disregarded - entity for Federal income tax purposes, such as a single - member limited liability company; this entity must hold either legal title to the property or other Qualified Indicia of Ownership.

for accounting / tax purposes, talk to an accountant who can advise you on which type of entity is best for each type of investment (land vs income, buy & hold vs flip, etc).

For example, a single member limited liability company (LLC) is considered by the Internal Revenue Service (IRS) to be a disregarded entity for income tax reporting purposFor example, a single member limited liability company (LLC) is considered by the Internal Revenue Service (IRS) to be a disregarded entity for income tax reporting purposfor income tax reporting purposes.