Apr 29, 2011 17:21
13 yrs ago
English term
qualified electing fund
English to Czech
Law/Patents
Investment / Securities
limited partnership investment funds
Dobrý podvečer znovu.
Hledám český překlad výrazu "qualified electing fund" v níže uvedeném kontextu. Jedná se zřejmě o volitelný režim zdanění dle amerického daňového zákoníku.
S díky. Lenka
In the event that the General Partner does determine that the Partnership does own an interest in a PFIC, the General Partner shall (i) notify such Limited Partner and (ii) upon request of such Limited Partner, use commercially reasonable efforts to provide such Limited Partner with such information as it may reasonably request to file on a timely basis and maintain a "qualified electing fund" election with respect to any such PFIC pursuant to section 1295 of the Code, provided that, in the case of a PFIC that the Partnership does not control directly or indirectly, the General Partner will be deemed to have fulfilled its obligations under this Section 4.7 if it has made a good faith request to the PFIC for such information
Hledám český překlad výrazu "qualified electing fund" v níže uvedeném kontextu. Jedná se zřejmě o volitelný režim zdanění dle amerického daňového zákoníku.
S díky. Lenka
In the event that the General Partner does determine that the Partnership does own an interest in a PFIC, the General Partner shall (i) notify such Limited Partner and (ii) upon request of such Limited Partner, use commercially reasonable efforts to provide such Limited Partner with such information as it may reasonably request to file on a timely basis and maintain a "qualified electing fund" election with respect to any such PFIC pursuant to section 1295 of the Code, provided that, in the case of a PFIC that the Partnership does not control directly or indirectly, the General Partner will be deemed to have fulfilled its obligations under this Section 4.7 if it has made a good faith request to the PFIC for such information
Proposed translations
(Czech)
| 4 +1 | QEF |
Hannah Geiger (X)
|
Proposed translations
+1
1 hr
QEF
Declined
V odkazu je dalekosáhlé vysvětlení, a jelikož ve Vašem odkazu dávají PFIC což se toho týká, myslím že se musí dát QEF což české odkazy běžně používají
http://www.zentiva.cz/download/prospekt/U47380Aprospekt.pdf
Qualified Electing Fund (QEF)
A PFIC is a QEF if the U.S. person who is a direct or indirect shareholder of the PFIC elects (under section 1295) to treat the PFIC as a QEF. See the instructions for Election A on page 2 for information on making this election.
Tax Consequences for Shareholders of a QEF
• A shareholder of a QEF must annually include in gross income as ordinary income its pro rata share of the ordinary earnings and as long-term capital gain the net capital gain of the QEF.
• The shareholder may elect to extend the time for payment of tax on its share of the undistributed earnings of the QEF (Election D) until the QEF election is terminated.
• The shareholder may make a deemed sale election (Election B) or a deemed dividend election (Election C) to purge the section 1291 fund years from its holding period.
http://www.irs.gov/instructions/i8621/ch01.html#d0e164
http://www.zentiva.cz/download/prospekt/U47380Aprospekt.pdf
Qualified Electing Fund (QEF)
A PFIC is a QEF if the U.S. person who is a direct or indirect shareholder of the PFIC elects (under section 1295) to treat the PFIC as a QEF. See the instructions for Election A on page 2 for information on making this election.
Tax Consequences for Shareholders of a QEF
• A shareholder of a QEF must annually include in gross income as ordinary income its pro rata share of the ordinary earnings and as long-term capital gain the net capital gain of the QEF.
• The shareholder may elect to extend the time for payment of tax on its share of the undistributed earnings of the QEF (Election D) until the QEF election is terminated.
• The shareholder may make a deemed sale election (Election B) or a deemed dividend election (Election C) to purge the section 1291 fund years from its holding period.
http://www.irs.gov/instructions/i8621/ch01.html#d0e164
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