Foreign use and indirect foreign Sample Clauses

Foreign use and indirect foreign use—foreign reverse hybrid structure and dis- regarded payments. (i) Facts. P owns DE1X. DE1X owns 99 percent and S owns 1 percent of FRHX, a Country X partnership that elected to be treated as a corporation for U.S. tax purposes. FRHX conducts a trade or business in Country X. In year 1, DE1X incurs interest 26 CFR Ch. I (4–1–11 Edition) expense on a third-party loan, which con- stitutes a dual consolidated loss attributable to P’s interest in DE1X. In year 1, for Coun- try X tax purposes, DE1X takes into account its distributive share of income generated by FRHX and offsets such income with its inter- est expense.
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Related to Foreign use and indirect foreign

  • Nonresident/Foreign Contractors The Contractor shall procure and maintain during the life of this contract:

  • Foreign Ownership Seller is not a “foreign person” as that term is defined in the U.S. Internal Revenue Code of 1986, as amended, and the regulations promulgated pursuant thereto, and Buyer has no obligation under Section 1445 of the U.S. Internal Revenue Code of 1986, as amended, to withhold and pay over to the U.S. Internal Revenue Service any part of the “amount realized” by Seller in the transaction contemplated hereby (as such term is defined in the regulations issued under said Section 1445).

  • Agricultural Export Subsidies 1. The Parties share the objective of the multilateral elimination of export subsidies for agricultural goods and shall work together toward an agreement in the World Trade Organization to eliminate those subsidies and prevent their reintroduction in any form.

  • Export Control Laws The Company has conducted its export transactions in accordance in all material respects with applicable provisions of United States export control laws and regulations, including but not limited to the Export Administration Act and implementing Export Administration Regulations.

  • Foreign Terrorists Organizations Contractor represents and warrants that it is not engaged in business with Iran, Sudan, or a foreign terrorist organization, as prohibited by Section 2252.152 of the Texas Government Code.

  • Foreign Contractor If Contractor is not domiciled in or registered to do business in the State of Oregon, Contractor shall promptly provide to the Oregon Department of Revenue and the Secretary of State Corporation Division all information required by those agencies relative to this Contract. Contractor shall demonstrate its legal capacity to perform the Services under this Contract in the State of Oregon prior to entering into this Contract.

  • Export Subsidies 1. The Parties and Signatory Parties share the goal of achieving the multilateral elimination of export subsidies for agricultural products and shall cooperate in efforts to achieve an agreement within the framework of the WTO to eliminate such subsidies.

  • Certification Regarding Prohibition of Boycotting Israel (Tex Gov. Code 2271) If (a) Vendor is not a sole proprietorship; (b) Vendor has ten (10) or more full-time employees; and (c) this Agreement or any agreement with a TIPS Member under this procurement has value of $100,000 or more, the following certification shall apply; otherwise, this certification is not required. Vendor certifies, where applicable, that neither the Vendor, nor any affiliate, subsidiary, or parent company of Vendor, if any, boycotts Israel, and Vendor agrees that Vendor and Vendor Companies will not boycott Israel during the term of this Agreement. For purposes of this Agreement, the term “boycott” shall mean and include refusing to deal with, terminating business activities with, or otherwise taking any action that is intended to penalize, inflict economic harm on, or limit commercial relations with Israel, or with a person or entity doing business in Israel or in an Israeli-controlled territory but does not include an action made for ordinary business purposes. When applicable, does Vendor certify? Yes

  • Foreign Terrorist Organizations Contractor represents and warrants that it is not engaged in business with Iran, Sudan, or a foreign terrorist organization, as prohibited by Section 2252.152 of the Texas Government Code.

  • United States and Canada For warranty service or information about how to obtain a refund for software acquired in the United States and Canada, contact Microsoft at  (800) MICROSOFT;  Microsoft Customer Service and Support, Xxx Xxxxxxxxx Xxx, Xxxxxxx, XX 00000-6399; or  visit xxx.xxxxxxxxx.xxx/xxxx/xxxxxxxxx.xxx.

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