Traduction de «caisse d'actions de sociétés américaines » (Français → Anglais) :

Mr. Davidson: There is no question that the mutual fund industry has such an volume of cash to invest that it is taking an increasing share of the equities of U.S. corporations.

Apple Sales International and Apple Operations Europe are two Irish incorporated companies that are fully-owned by the Apple group, ultimately controlled by the US parent, Apple Inc. They hold the rights to use Apple's intellectual property to sell and manufacture Apple products outside North and South America under a so-called 'cost-sharing agreement' with Apple Inc. Under this agreement, Apple Sales International and Apple Operations Europe make yearly payments to Apple in the US to fund research and development efforts conducted on behalf of the Irish companies in the US.

For purposes of subparagraph 2(b) of Article XXIX (Miscellaneous Rules) of the Convention, “income deemed under the domestic law of the United States to arise from such sources” shall consist of gains from the sale or exchange of stock of a U.S. company or debt obligations of a U.S. person, the United States, a State, or a political subdivision thereof, or the District of Columbia, gains from property (other than stock or debt obligations) located in the United States, and, in certain cases, income or gain derived from the sale of stock of a non-U.S. company or a disposition of property contributed to such non-U.S. company where such com ...[+++]pany would be a controlled foreign corporation with respect to the person if such person had continued to be a U.S. person.

We still have a number of other corporate entities, such as boards of trade, trade unions, pension fund societies that have old legislation around, but the three main ones are a share corporation, a non-share corporation or a co-op — and those three will pretty much cover most of the business environment.