CFC. Immediately after the Closing, the Company will not be a CFC as defined in the Code (or any successor thereto). The Company shall make due inquiry with its tax advisors on at least an annual basis regarding the Company’s status as a CFC and regarding whether any portion of the Company’s income is “subpart F income” (as defined in Section 952 of the Code).
Appears in 5 contracts
Samples: Preferred Share Purchase Agreement (Qiniu Ltd.), Series F Preferred Share Purchase Agreement (Qiniu Ltd.), Preferred Share Purchase Agreement (Qiniu Ltd.)
CFC. Immediately after the First Closing, the Company will not be a CFC as defined in the Code (or any successor thereto). The Company shall make due inquiry with its tax advisors on at least an annual basis regarding the Company’s status as a CFC and regarding whether any portion of the Company’s income is “subpart F income” (as defined in Section 952 of the Code).
Appears in 2 contracts
Samples: Series F Preferred Share Purchase Agreement (Qiniu Ltd.), Series F Preferred Share Purchase Agreement (Qiniu Ltd.)
CFC. Immediately after the Initial Closing, the Company will not be a CFC as defined in the Code (or any successor thereto). The Company shall make due inquiry with its tax advisors on at least an annual basis regarding the Company’s status as a CFC and regarding whether any portion of the Company’s income is “subpart F income” (as defined in Section 952 of the Code).
Appears in 1 contract
Samples: Series G Preferred Share Purchase Agreement (BEST Inc.)
