Questa nota fa parte del prospetto di US3696223946 GE 4,7 e dice che i cittadini non residenti negli Usa sono esenti da ritenuta federale negli Usa , ma non mi è chiaro cosa accadrà dal 1° Gennaio 2014
Non-U.S. Holders
If you are a non-resident alien individual or a foreign corporation that is the beneficial owner of the notes (a “non-U.S. holder”), the interest income that you derive in respect of the notes generally will be exempt from United States federal withholding tax. This exemption will apply to you provided that
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you do not actually or constructively own 10% or more of the combined voting power of all classes of our stock and you are not a controlled foreign corporation that is related, directly or indirectly to us through stock ownership and
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you provide a statement (generally, an Internal Revenue Service Form W-8BEN or a substitute therefor or successor thereto) signed under penalties of perjury that includes your name and address and certifies that you are a non-U.S. holder in compliance with applicable requirements (or satisfy certain documentary evidence requirements for establishing that you are a non-U.S. holder).
Notwithstanding the foregoing, subject to the “grandfather rule” described below, you may be subject to U.S. withholding tax with respect to payments of interest made after December 31, 2013 unless (x) if you (or any foreign intermediary through which you hold notes) are not a “foreign financial institution” (as defined below), you (or any such foreign intermediary through which you hold notes) have provided any required information with respect to your direct and indirect U.S. owners, if any; and (y) if you (or any intermediary through which you hold notes) are a “foreign financial institution” (as defined below), you (or any such foreign intermediary through which you hold notes) have (i) entered into an agreement with the U.S. government, pursuant to which you (or such intermediary) agree, among other responsibilities, to collect and provide to the U.S. tax authorities information about your (or such intermediary’s) direct and indirect U.S. accountholders and investors or (ii) complied with any requirements imposed on you (or such intermediary) pursuant to an intergovernmental agreement between the U.S. government and the government of a foreign country (an “IGA”). Under current guidance, pursuant to a “grandfather rule,” the withholding tax described in this paragraph will not apply to notes issued before January 1, 2013. According to public remarks by a senior U.S. government official, future guidance is expected to provide that the grandfather rule will be extended to include notes issued before January 1, 2014;
however, there can be no assurance that such withholding will not apply to notes issued prior to such date.
If you are a non-U.S. holder, any gain you realize on a sale, exchange or other disposition of notes generally will be exempt from United States federal income tax, including withholding tax. This exemption will not apply to you if: (i) your gain is effectively connected with your conduct of a trade or business in the United States; or (ii) you are an individual holder and are present in the United States for 183 days or more in the taxable year of the disposition and either your gain is attributable to an office or other fixed place of business that you maintain in the United States or you have a tax home in the United States. In addition, the gross proceeds from a sale, exchange, redemption or other taxable disposition of a note that is not subject to the grandfather rule described above effected after December 31, 2016 may be subject to withholding tax unless (x) if you (or any foreign intermediary through which you hold notes) are not a “foreign financial institution” (as defined below), you (or any such foreign intermediary through which you hold notes) have provided any required information with respect to your direct and indirect U.S. owners, if any; and (y) if you (or any intermediary through which you hold notes) are a “foreign financial institution” (as defined below), you (or any such foreign intermediary through which you hold notes) have (i) entered into an agreement with the U.S. government, pursuant to which you (or such intermediary) agree, among other responsibilities, to collect and provide to the U.S. tax authorities information about your (or such intermediary’s) direct and indirect U.S. accountholders and investors or (ii) complied with any requirements imposed on you (or such intermediary) pursuant to an IGA.
For the purpose of the preceding paragraphs, a “foreign financial institution” generally is a non-U.S. entity that (i) accepts deposits in the ordinary course of a banking or similar business, (ii) as a substantial portion of its business, holds financial assets for the account of others, (iii) is engaged (or holds itself out as being engaged) primarily in the business of investing, reinvesting, or trading in securities, partnership interests or commodities, or interests in securities, partnership interests, commodities or certain other financial instruments, or (iv) is an insurance company that meets certain requirements. However, if an entity is located in a country that has entered into an IGA, the types of entities that are subject to the obligations imposed on foreign financial institutions may differ somewhat from those described in this paragraph.
United States federal estate tax will not apply to a note held by you if at the time of death you were not a citizen or resident of the United States, you did not actually or constructively own 10 percent or more of the combined voting power of all classes of our stock and payments of interest on the note would not have been effectively connected with the conduct by you of a trade or business in the United States.
For purposes of applying the rules set forth under this heading “Non-U.S. Holders” to a note held