The document discusses the tax implications for non-U.S. holders of common stock, including conditions under which dividends and gains on disposition are subject to U.S. federal income tax. It outlines the requirements for claiming treaty benefits and avoiding backup withholding, as well as the conditions under which gains are taxable. The document also mentions the company's status regarding being a 'United States real property holding corporation.'
doj/DataSet10/EFTA01382398.pdf
{"title":"Amendment No. 3 to Form S-1","document_date":"2015-10-14","document_type":"legal","key_locations":["United States"],"document_subtype":"Securities Filing","key_organizations":["Internal Revenue Service"],"reference_numbers":["1646972","000119312515335826","d900395ds"]}