purchaser a certification stating, under penalties of perjury, that the transferor is not a foreign person
and containing the transferor's name, U.
source payments to foreign persons
are commonly exempt from withholding tax.
18) A domestically controlled REIT means a REIT in which at all times during the five-year period ending on the date of the disposition or of the distribution, as the case may be (or the shorter period if the REIT was in existence for less than five years), less than 50 percent in value of the stock was held directly or indirectly by foreign persons
Furnishing any technical data controlled under the ITAR to a foreign person
, whether in the United States or abroad.
v) A foreign person
would not be subject to withholding except to the extent of contingent payments, which are sourced as royalties.
source income and a foreign person
who derives income from the same transmission would have foreign source income.
persons (individuals and businesses) abroad and business activities in the United States by foreign persons
We have determined that the minimum quarterly cash distributions received by foreign persons
beginning in 2009 are subject to US income tax withholding under applicable Internal Revenue Service guidelines.
Thus, presumably, if a foreign person
contributes a USRPI to a partnership in exchange for a partnership interest in a Sec.
business by a foreign person
if it threatens national security under the socalled Exon-Florio Amendment.
TRIA provides for a federally funded backstop for insurers in the event of a "certified act of terrorism;" in particular, acts committed by one or more persons acting on behalf of a foreign person
or foreign interest.
The first way a foreign person
can achieve exemption from the withholding tax and be taxed on a net basis is to qualify its real estate operations as being "engaged in a U.