가끔 문서의 조각만 공유 받는 경우가 있는데,
이런 경우 문서 내에서 특정 표현을 어떻게 규정하는지 조금 애매한 경우가 많다.
그래서 가끔 다른 비슷한 문서를 찾아서 그 문서에서는 어떻게 그 개념을 정의하는지 참고할 때가 있다.
The U.S. Holder라고만 공유를 받아서..(나머지는 the Company, the 어쩌구...이런식으로 텀 정의 되는 부분을 공유 받았음)
관용적으로 다른데서는 어떻게 쓰이는 표현인가 한번 더 점검해본다. 좀 새로운걸 번역할때는 내가 맞게 이해했는지 불안하기에... 통상적으로 어떻게 쓰이나 크로스 체크라도 해본다.
물론 각 서류마다 용어 정의가 다르므로 어디까지나 참고용이다.
다행히 아래 설명이 일반적인 용례가 맞는 것 같다. 출처는 아래.
As used herein, a "U.S. holder" means a beneficial owner of a note that is for U.S. federal income tax purposes
(i) an individual citizen or resident of the United States,
(ii) a corporation or other entity classified as a corporation for these purposes, created or organized in or under the laws of the United States, any state or any political subdivision thereof or the District of Columbia,
(iii) an estate the income of which is subject to U.S. federal income taxation regardless of its source or
(iv) a trust
(X) that is subject to the primary supervision of a court within the United States and the control of one or more United States persons as described in section 7701(a)(30) of the Code or
(Y) that has a valid election in effect under applicable U.S. Treasury Regulations to be treated as a United States person.
VIRGIN MEDIA INVESTMENT HOLDINGS LTD - 424B5 - 20091105 - TAXATION
Material United States Federal Income Tax Considerations The following summary describes the material U.S. federal income tax consequences of the ownership and disposition of the notes by a U.S. holder, as defined below. The discussion set forth be
edgar.brand.edgar-online.com
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U.S. source income: 미국 원천소득
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..if the accrual basis U.S. Holder makes the election described above...
위 문장에서 발생주의 적용 납세body의 making election이 뭔고하니..
§ 1.466-3 Manner of and time for making election under section 466.
(a) In general. Section 466 provides a special method of accounting for accrual basis taxpayers who issue qualified discount coupons (as defined in section 466(b)). In order to use the special method under section 466, a taxpayer must make an election with respect to the trade or business in connection with which the qualified discount coupons are issued. If a taxpayer issues qualified discount coupons in connection with more than one trade or business, the taxpayer may use the special method of accounting under section 466 only with respect to the qualified discount coupons issued in connection with a trade or business for which an election is made. The election must be made in the manner prescribed in this section. The election does not require the prior consent of the Internal Revenue Service. An election under section 466 is effective for the taxable year for which it is made and for all subsequent taxable years, unless the taxpayer secures the prior consent of the Internal Revenue Service to revoke such election.
(b) Manner of and time for making election -
(1) General rule. Except as provided in paragraph (b)(2) of this section, an election is made under section 466 and this section by filing a statement of election containing the information described in paragraph (c) of this section with the taxpayer's income tax return for the taxpayer's first taxable year for which the election is made. The election must be made not later than the time prescribed by law (including extensions thereof) for filing the income tax return for the first taxable year for which the election is made. Thus, the election may not be made for a taxable year by filing an amended income tax return after the time prescribed (including extensions) for filing the original return for such year.
(2) Transitional rule. If the last day of the time prescribed by law (including extensions thereof) for filing a taxpayer's income tax return for the taxpayer's first taxable year ending after December 31, 1978, falls before December 3, 1979, and the taxpayer does not make an election under section 466 with respect to such taxable year in the manner prescribed by paragraph (b)(1) of this section, an election is made under section 466 and this section with respect to such taxable year if -
(i) Within the time prescribed by law (including extensions thereof) for filing the taxpayer's income tax return for such taxable year, the taxpayer has made a reasonable effort to notify the Commissioner of the taxpayer's intent to make an election under section 466 with respect to such taxable year, and
(ii) Before January 2, 1980, the taxpayer files a statement of election
containing the information described in paragraph (c) of this section to be associated with the taxpayer's income tax return for such taxable year.
For purposes of paragraph (b)(2)(i) of this section, a reasonable effort to notify the Commissioner of an intent to make an election under section 466 with respect to a taxable year includes the timely filing of an income tax return for such taxable year if the taxable income reported on the return reflects a deduction for the redemption costs of qualified discount coupons as determined under section 466(a).
(c) Required information. The statement of election required by paragraph (b) of this section must indicate that the taxpayer (identified by name, address, and taxpayer identification number) is making an election under section 466 and must set forth the following information:
(1) A description of each trade or business for which the election is made;
(2) The first taxable year for which the election is made;
(3) The redemption period (as defined in section 466(c)(2)) for each trade or business for which the election is made;
(4) If the taxpayer is required to establish a suspense account under section 466(e) for a trade or business for which the election is made, the initial opening balance of such account (as defined in section 466(e)(2)) for each such trade or business; and
(5) In the case of an election under section 466 that results in a net increase in taxable income under section 481(a)(2), the amount of such net increase.
The statement of election should be made on a Form 3115, which need contain no information other than that required by this paragraph or paragraph (c) of § 1.466-4.
[T.D. 8022, 50 FR 18477, May 1, 1985]