This document is a legal discussion on the U.S. federal income tax implications for non-U.S. holders of Class A common stock, based on the Internal Revenue Code of 1986 and related regulations. It outlines the definition of a non-U.S. holder, the tax treatment of partnerships, and the implications of holding shares as a capital asset. The document also discusses the withholding tax on dividends and advises prospective investors to consult tax advisors for comprehensive tax implications.
doj/DataSet10/EFTA01377772.pdf
{"document_date":"2015-11-06","document_type":"legal","document_subtype":"S-1/A Filing","reference_numbers":["DB-SDNY-0074924","SDNY_GM_00221108","EFTA01377772"]}