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AYR » Topics » One or more of our Irish subsidiaries could fail to qualify for treaty benefits, which would subject certain of their income to U.S. federal income taxation, which would adversely affect our business and result in decreased cash available for distributionThese excerpts taken from the AYR 10-K filed Mar 2, 2009. One or
more of our Irish subsidiaries could fail to qualify for treaty
benefits, which would subject certain of their income to U.S.
federal income taxation, which would adversely affect our
business and result in decreased cash available for distribution
to our shareholders.
Qualification for the benefits of the Irish Treaty depends on
many factors, including being able to establish the identity of
the ultimate beneficial owners of our common shares. Each of the
Irish subsidiaries may not satisfy all the requirements of the
Irish Treaty and thereby may not qualify each year for the
benefits of the Irish Treaty or may be deemed to have a
permanent establishment in the United States. Moreover, the
provisions of the Irish Treaty may change. Failure to so
qualify, or to be deemed to have a permanent establishment in
the United States, could result in the rental income from
aircraft used for flights within the United States being subject
to increased U.S. federal income taxation. The imposition
of such taxes would adversely affect our business and would
result in decreased cash available for distribution to our
shareholders.
One or more of our Irish subsidiaries could fail to qualify for treaty benefits, which would subject certain of their income to U.S. federal income taxation, which would adversely affect our business and result in decreased cash available for distribution to our shareholders. Qualification for the benefits of the Irish Treaty depends on many factors, including being able to establish the identity of the ultimate beneficial owners of our common shares. Each of the Irish subsidiaries may not satisfy all the requirements of the Irish Treaty and thereby may not qualify each year for the benefits of the Irish Treaty or may be deemed to have a permanent establishment in the United States. Moreover, the provisions of the Irish Treaty may change. Failure to so qualify, or to be deemed to have a permanent establishment in the United States, could result in the rental income from aircraft used for flights within the United States being subject to increased U.S. federal income taxation. The imposition of such taxes would adversely affect our business and would result in decreased cash available for distribution to our shareholders. This excerpt taken from the AYR 10-Q filed Nov 17, 2008. One or
more of our Irish subsidiaries could fail to qualify for treaty
benefits, which would subject certain of their income to U.S.
federal income taxation, which would adversely affect our
business and result in decreased cash available for distribution
to our shareholders.
Qualification for the benefits of the Irish Treaty depends on
many factors, including being able to establish the identity of
the ultimate beneficial owners of our common shares. Each of the
Irish subsidiaries may not satisfy all the requirements of the
Irish Treaty and thereby may not qualify each year for the
benefits of the Irish Treaty or may be deemed to have a
permanent establishment in the United States. Moreover, the
provisions of the Irish Treaty may change. Failure to so
qualify, or to be deemed to have a permanent establishment in
the United States, could result in the rental income from
aircraft used for flights within the United States being subject
to U.S. federal income taxation at a maximum rate of 35%
(plus the 30% U.S. federal branch profits tax on
effectively connected earnings and profits). The imposition of
such taxes would adversely affect our business and would result
in decreased cash available for distribution to our shareholders.
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