69 unchanged sentences
alternative minimum, U.S.
−Removed: estate and gift, U.S.
+Added: federal estate and gift, U.S.
state and local, and non-U.S.
50 unchanged sentences
federal rate on “qualified dividend income,” provided that we are a “qualified foreign corporation,” the stock on which the dividend is paid is held for a minimum holding period, and other requirements are satisfied.
−Removed: A “qualified foreign corporation” includes a foreign corporation that is not a PFIC in the year of the distribution or in the prior taxable year and that is eligible for the benefits of an income tax treaty with the United States that contains an exchange of information provision and has been determined by the United States Treasury Department to be satisfactory for purposes of the legislation (such as the Canada-U.S.
+Added: A “qualified foreign corporation” includes
+Added: a foreign corporation that is not a PFIC in the year of the distribution or in the prior taxable year and that is eligible for the benefits of an income tax treaty with the United States that contains an exchange of information provision and has been determined by the United States Treasury Department to be satisfactory for purposes of the legislation (such as the Canada-U.S.
Tax Convention).
44 unchanged sentences
federal income tax liability on a dollar-for-dollar basis, whereas a deduction will reduce a U.S.
−Removed: Holder’s income that is subject to U.S.
+Added: income that is subject to U.S.
federal income tax.
25 unchanged sentences
person, and any interest in a foreign entity.
−Removed: Holders may be subject to these reporting requirements unless their
−Removed: common shares are held in an account at certain financial institutions.
+Added: Holders may be subject to these reporting requirements unless their common shares are held in an account at certain financial institutions.
Significant penalties may apply for failure to satisfy applicable reporting obligations.
32 unchanged sentences
United States Treasury Regulations provide, subject to the election described in the following paragraph, that solely for purposes of this additional tax, distributions of previously taxed income will be treated as dividends and included in net investment income subject to the additional 3.8% tax.
−Removed: Additionally, to determine the amount of any capital gain from the sale or other taxable disposition of common shares that will be subject to the additional tax on net investment
−Removed: income, a U.S.
+Added: Additionally, to determine the amount of any capital gain from the sale or other taxable disposition of common shares that will be subject to the additional tax on net investment income, a U.S.
Holder who has made a “qualified electing fund” election will be required to recalculate its basis in the common shares excluding basis adjustments resulting from the “qualified electing fund” election.
15 unchanged sentences
Holders who are C corporations, as they are entitled to a 50% deduction (37.5% after 2025) of the GILTI income as well as a reduced foreign tax credit on foreign taxes paid on the GILTI income.
−Removed: Holders who are individuals, estates or trusts may pay substantially more tax on GILTI income, as they are subject to ordinary tax rates (ranging from 10% to 37% plus the net investment income tax of 3.8%).
+Added: Holders who are individuals, estates or trusts may pay substantially more tax on GILTI income, as they are subject to ordinary tax rates (ranging from 10% to 37% plus
+Added: the net investment income tax of 3.8%).
Holders are not entitled to a deduction on GILTI income or a reduced foreign tax credit.
19 unchanged sentences
Holder or a person in (a) directly or indirectly hold membership interests, held shares and/or rights to acquire shares representing 25% or more of the issued shares of any class of our capital stock;
−Removed: and (b) more than 50% of the fair market value of our common stock was derived
−Removed: directly or indirectly from one or any combination of (i) real or immovable property situated in Canada, (ii) Canadian resource properties, (iii) timber resource properties, and (iv) options in respect of, or interests in, or for civil law rights in, property described in any of (i) to (iii).
+Added: and (b) more than 50% of the fair market value of our common stock was derived directly or indirectly from one or any combination of (i) real or immovable property situated in Canada, (ii) Canadian resource properties, (iii) timber resource properties, and (iv) options in respect of, or interests in, or for civil law rights in, property described in any of (i) to (iii).
Holders whose common shares constitute “taxable Canadian property” should consult their own tax advisors for advice having regard to their particular circumstances.
11 unchanged sentences
Compared sentence by sentence after normalising whitespace, quotation marks, case and digits, so re-formatting and restated figures do not read as changed language. Wording changes appear as one removal and one addition. The current filing and the prior one are authoritative.