Instructions For Schedule S (Form 1120-F) - 2016 Page 4
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4country and meets the publicly-traded
and the qualified foreign country in
Line 16b. Enter the applicable
test of Regulations section 1.883-2(a).
which the airline is organized,
two-letter codes from the list of country
(D) A not-for-profit organization
provided the United States has not
codes at
described in Regulations section
waived the ownership requirement in
Line 16c. Enter the percentage of the
1.883-4(b)(4) that is not a pension
the Air Services Agreement, or that
value of the outstanding shares that is
fund as defined in Regulations section
the ownership requirement has not
owned by the qualified shareholders as
1.883-4(b)(5) and that is organized in
otherwise been made ineffective.
bearer shares maintained in a
a qualified foreign country.
2. Does not own its interest in the
dematerialized or immobilized book-entry
(E) An individual beneficiary of a
foreign corporation through bearer shares,
system. In determining the percentage to
pension fund (as defined in
either directly or by applying the attribution
enter on line 16c, the numerator is the total
Regulations section 1.883-4(b)(5)(iv))
rules of Regulations section 1.883-4(c).
value of bearer shares owned by the
that is administered in or by a qualified
However, the shareholder may own its
qualified shareholders and maintained in a
foreign country, who is treated as a
interest in the foreign corporation through
dematerialized or immobilized book-entry
resident under Regulations section
bearer shares if such shares are
system. The denominator is the total value
1.883-4(d)(3)(iii) of a qualified foreign
maintained in a dematerialized or
of all outstanding shares of the
country, or
immobilized book-entry system.
corporation, including the value of any
(F) A shareholder of a foreign
3. Provides to the foreign corporation
bearer shares.
corporation that is an airline covered
the documentation required in Regulations
by a bilateral Air Services Agreement
section 1.883-4(d).
in force between the United States
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