The document discusses the tax implications for non-U.S. Holders of common stock, including withholding tax rates, conditions for tax exemptions, and gain on disposition of stock. It outlines the requirements for claiming tax treaty benefits and the conditions under which gains are subject to U.S. federal income tax.
doj/DataSet10/EFTA01381326.pdf
{"document_type":"legal","document_subtype":"Form S-1","reference_numbers":["DB-SDNY-0080214","SDNY_GM_00226398","EFTA01381326"]}