(iv) multi-party recognition agreements. The consent of the person of the United States to the recognition of benefit in accordance with Dense1.367 A) -8 contains appropriate provisions that are consistent with the principles of S. 1.367 A) -8. See Examples 5 and 5A of this section and see 1.367 (a)-8 (d) (9). (j) triggering events. Unless there is a provision in this section, the U.S. assignor must recognize the benefit pursuant to the profit recognition agreement covered in paragraph (c) (1) (i) of this section, if it appears in this section in paragraphs j) (1) to (10) of this section (trigger event). This paragraph (j) generally requires the U.S. assignor to account for earnings (and pay interest on the additional tax under paragraph (c) (1) (v) of this section, as long as the transferred shares or securities are sold directly or indirectly. This paragraph (j) also requires the U.S. assignor to recognize the benefit of the recognition agreement, in some cases where it is not appropriate for the recognition agreement to be maintained. At point (k) in this section, you will find exceptions available for certain events that would otherwise constitute trigger events in accordance with this paragraph (j).

See paragraph o) of this section, for certain events that, subject to a recognition agreement, end or reduce the amount of profits. 2. For the purposes of paragraph d) (2) (vi) (1) (1) of this section, a turnover is considered to be the primary purpose of tax evasion if, within two years of the transfer described in paragraph d) (vi) (vi) (a) (A) of this section, the foreign acquisition company has shares of the nationally controlled entity (in a recognition or non-recognition transaction). The rule of paragraph d, paragraph 2, point vi) (D) (2), does not apply where the acquired capital company (or foreign company acquiring on behalf of the acquired domestic company) demonstrates, to the Commissioner`s satisfaction, that U.S. tax evasion was not the primary purpose of the transaction. To this end, the transfer of the domesticly controlled entity by the foreign acquisition company is considered non-primary subject to tax evasion, more than five years after the conclusion of the transfer described in paragraph (d) (2) (vi) (A) of this section. There are a large number of cross-border transactions that can trigger a Section 367 reporting obligation, including: v) payment and declaration of interest. Interest is payable on additional taxes payable on the profit recognized by the U.S. assignor pursuant to paragraph (c) (1) (i) of this section. Interest payable is set on the basis of the rates provided for in Section 6621, for the period between the date prescribed for filing the U.S. Cedant`s income tax return for the year of the first assignment and the date on which the additional tax due was paid.