Controlled Foreign Corporation definition

Controlled Foreign Corporation means “controlled foreign corporation” as defined in the Tax Code.

Controlled Foreign Corporation means a Subsidiary that is a controlled foreign corporation under Section 957 of the Code.

Controlled Foreign Corporation means any Subsidiary which is (i) a “controlled foreign corporation” (within the meaning of Section 957 of the Code), (ii) a subsidiary substantially all the assets of which consist of equity in Subsidiaries described in clause (i) of this definition, or (iii) an entity treated as disregarded for U.S. federal income tax purposes that owns more than 65% of the voting stock of a Subsidiary described in clause (i) or (ii) of this definition.

Examples of Controlled Foreign Corporation in a sentence

• Local sporting events, especially football, were covered, but attention was also given to church affairs, poetry and literary extracts, in addition to reviews of concerts, recitals and plays.

• ForU.S. income tax purposes, the Subsidiary is a Controlled Foreign Corporation (“CFC”) not subject to U.S. income taxes.

• Modification of Stock Attribution Rules for Determining Status as a Controlled Foreign Corporation (sec.

• Corporate taxpayers are obliged to fill in the “The Form on Transfer Pricing, Controlled Foreign Corporation and Thin Capital” regarding the purchases or sales of goods or services they perform with related parties during a fiscal period and submit it to their tax office in the attachment of the corporate tax return.

• Assets invested in a Controlled Foreign Corporation for the purpose of investing in certain types of instruments such as, but not limited to, commodities.

More Definitions of Controlled Foreign Corporation

Controlled Foreign Corporation means any foreign corporation if more than 50 percent of the total combined voting power of all classes of stock of such corporation entitled to vote, or the total value of the stock of such corporation, is owned, or is considered as owned, by “United States shareholders” on any day during the taxable year of such foreign corporation. The term a “United States shareholder” means, with respect to any foreign corporation, a United States person who owns, or is considered as owning, 10 percent or more of the total combined voting power of all classes of stock entitled to vote of such foreign corporation.

Controlled Foreign Corporation means any Subsidiary which is (i) a “controlled foreign corporation” (within the meaning of Section 957 of the Code), (ii) a Subsidiary substantially all the assets of which consist (directly or indirectly through one or more flow-through entities) of Equity Interests and/or indebtedness of one or more Subsidiaries described in clause (i) of this definition, or (iii) an entity treated as disregarded for U.S. federal income tax purposes and substantially all of the assets of which consist (directly or indirectly through one or more flow-through entities) of the Equity Interests and/or indebtedness of one or more Subsidiaries described in clause (i) or (ii) of this definition.

Controlled Foreign Corporation means a “controlled foreign corporation” as defined in the Internal Revenue Code of 1986.

Controlled Foreign Corporation means any Subsidiary which is (i) a “controlled foreign corporation” (within the meaning of Section 957 of the Code), (ii) a subsidiary substantially all the assets of which consist of debt or equity in Subsidiaries described in clause (i) of this definition, or (iii) an entity treated as disregarded for U.S. federal income tax purposes that owns more than 65% of the voting stock of a Subsidiary described in clause (i) or (ii) of this definition.

Controlled Foreign Corporation means a “controlled foreign corporation” as defined in the Internal Revenue Code.

Controlled Foreign Corporation means a controlled foreign corporation within the meaning of Section 957(a) of the Code.

Controlled Foreign Corporation means a “controlled foreign corporation” as defined in Section 957(a) of the Code.