8/26/2023 0 Comments Navistar ndm![]() Seller has the meaning set forth in the Preamble. ![]() GMAC GMAC Mortgage Corporation and its successors and assigns, in its capacity as Servicer of the GMAC Mortgage Loans. Basic Rate Interface-ISDN (BRI-ISDN) provides for a digital transmission of two (2) 64 Kbps bearer channels and one (1) 16 Kbps data channel (2B+D).ĭCC means the Dutch Civil Code (Burgerlijk Wetboek). Integrated Services Digital Network (ISDN means a switched network service that provides end-to-end digital connectivity for the simultaneous transmission of voice and data. PMC means Project Management Consultant who is designated supervision agency during execution of this project.ĮMC EMC Mortgage Corporation, or its successor in interest. Intel shall have the meaning set forth in the preamble to this Agreement. Triad means Triad Financial Corporation, a California corporation, as predecessor in interest to Santander Consumer.ĪFSL means Australian Financial Services Licence.ĭCFS means COUNTY’s Department of Children and Family Services RFS means Request for Selection (RFS)/Bid document/Tender documentĪCS means “asset-controlling supplier” as that term is defined in the Cap and Trade Regulations. Impact of investing in other Collective Investment Schemes by a Fund Special rules apply in certain circumstances for determining the reportable income of a RFSC of a sub-fund which invests in other funds which are themselves registered with HMRC as UK reporting funds. ![]() The general comments at C.1 and C.2 are prepared on the basis that none of the RFSC in the Company are categorised as ‘bond funds’ under the relevant UK legislation.ĭ.1 Capital gains UK tax resident shareholders may be liable to capital gains tax in respect of capital disposals of their non RFSC Shares.ĭ.2 Income received from non RFSC A UK tax resident investor in a non RFSC should only have a potential liability to UK tax in respect of actual distributions received. The deemed distributions received by the corporate throughout their period of ownership of the RFSC Shares may in certain circumstances represent additional base cost on sale of the RFSC Shares. If reporting fund status is revoked by HMRC for any RFSC, that RFSC will be unable to regain reporting fund status and will thereafter be permanently outside the reporting fund regime.Ĭ.2 Income and deemed distributions – general principles Broadly speaking, an investor will be taxed on income accruing in a RFSC on an annual basis, rather than when it is distributed to the investor. We would not expect these provisions to apply to income relating to a share class which has been certified by HMRC as a RFSC. This is the case irrespective of whether any income is physically distributed to a RFSC shareholder in any period in respect of their holding. Where a share class has not been certified as a RFSC, the provisions could apply but there are potential exemptions available where the transactions are genuine commercial transactions and avoidance of tax was not the purpose or one of the purposes for which the transactions were effected.
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