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n to the source of Validus Holdings' earnings and profits for the year in which the dividend is paid. Any amounts required to be included in a U.S. Holder's gross income under the CFC rules or the RPII rules described below, and any amounts treated as dividends under Section 1248 of the Code, would als
"Excess Distribution" (as defined below) received in respect of Series A Preference Shares as if such items had been earned ratably over each day in the U.S. Holder's holding period (or a portion thereof) for the Series A Preference Shares. The amounts allocated to the taxable year during which the gain is realize
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ws. For purposes of this summary, the term "U.S. Holder" means a beneficial owner of Shares that, for US.
ween the amount of cash received (determined before the deduction, if any, of any withholding tax) in exchange for Shares pursuant to the Offer and the U.S. Holder's adjusted tax basis in such Shares. Any such gain or loss will be long-term capital gain or loss if a U.S. Holder's holding period for such Shares is
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ws. For purposes of this summary, the term "U.S. Holder" means a beneficial owner of Shares that, for US.
ween the amount of cash received (determined before the deduction, if any, of any withholding tax) in exchange for Shares pursuant to the Offer and the U.S. Holder's adjusted tax basis in such Shares. Any such gain or loss will be long-term capital gain or loss if a U.S. Holder's holding period for such Shares is
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he PFIC rules, which are described below. A U.S. Holder that is a U.S. 10% Shareholder of the Issuer subj
any year which are greater than 125% of the average annual distribution received by such U.S. Holder in the shorter of the three preceding years or the U.S. Holder's holding period or, if shorter, the U.S. Holders holding period for the Preferred Shares) by the Issuer and upon a disposition of the Preferred Share
2 mentions1 same-page
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ws. For purposes of this summary, the term "U.S. Holder" means a beneficial owner of Shares that, for US.
ween the amount of cash received (determined before the deduction, if any, of any withholding tax) in exchange for Shares pursuant to the Offer and the U.S. Holder's adjusted tax basis in such Shares. Any such gain or loss will be long-term capital gain or loss if a U.S. Holder's holding period for such Shares is
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Mutual Connections (3)
Entities connected to both Eric Holder and the U.S. Holder's