Extract to table

This test has two prongs, both of which must be satisfied: Ownership Prong

More than 50% of the aggregate vote and value of Luminex Holdings' shares must be owned, directly or indirectly, by persons who are themselves "equivalent beneficiaries

Less than 50% of Luminex Holdings' gross income must be paid or accrued, directly or indirectly, to persons who are not residents of the United States in the form of payments that are deductible for U

For LOB purposes, the residency and "equivalent beneficiary" status of each equity holder (or, in the case of fiscally transparent entities such as limited partnerships, the underlying investors therein) must be determined

Based on the available information, the ownership prong analysis is as follows: To satisfy the ownership prong, more than 50% of the aggregate vote and value of Luminex Holdings must be attributable to equivalent beneficiaries

9% non-qualifying interest, the remaining holders must collectively account for more than approximately 56