The document discusses U.S. federal income tax implications for Non-U.S. holders of common stock, including conditions under which gains are taxable, potential withholding requirements, and the impact of FATCA regulations. It outlines scenarios where Non-U.S. holders may be subject to U.S. taxes, such as if the company is a U.S. real property holding corporation or if the holder has significant ownership. It also covers information reporting, backup withholding, and FATCA withholding taxes.
documents/vol00010-efta01366398-pdf.pdf
{"document_type":"legal","reference_numbers":["DB-SDNY-0057924","SDNY_GM_00204108","EFTA01366398"]}