Instructions For Schedule S (Form 1120-F) - 2015 Page 4

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subdivision or local authority of such
by a bilateral Air Services Agreement
Line 16b. Enter the applicable
country).
in force between the United States
two-letter codes from the list of country
(C) A foreign corporation that is
and the qualified foreign country in
codes at
organized in a qualified foreign
which the airline is organized,
Line 16c. Enter the percentage of the
country and meets the publicly-traded
provided the United States has not
value of the outstanding shares that is
test of Regulations section 1.883-2(a).
waived the ownership requirement in
owned by the qualified shareholders as
(D) A not-for-profit organization
the Air Services Agreement, or that
bearer shares maintained in a
described in Regulations section
the ownership requirement has not
dematerialized or immobilized book-entry
1.883-4(b)(4) that is not a pension
otherwise been made ineffective.
system. In determining the percentage to
fund as defined in Regulations section
2. Does not own its interest in the
enter on line 16c, the numerator is the total
1.883-4(b)(5) and that is organized in
foreign corporation through bearer shares,
value of bearer shares owned by the
a qualified foreign country.
either directly or by applying the attribution
qualified shareholders and maintained in a
(E) An individual beneficiary of a
rules of Regulations section 1.883-4(c).
dematerialized or immobilized book-entry
pension fund (as defined in
However, the shareholder may own its
system. The denominator is the total value
Regulations section 1.883-4(b)(5)(iv))
interest in the foreign corporation through
of all outstanding shares of the
that is administered in or by a qualified
bearer shares if such shares are
corporation, including the value of any
foreign country, who is treated as a
maintained in a dematerialized or
bearer shares.
resident under Regulations section
immobilized book-entry system.
1.883-4(d)(3)(iii) of a qualified foreign
3. Provides to the foreign corporation
country, or
the documentation required in Regulations
(F) A shareholder of a foreign
section 1.883-4(d).
corporation that is an airline covered
-4-

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