Passive Foreign Investment Company. To the best knowledge of the Teekay Parties, after consultation with United States federal income tax counsel, none of the Teekay Entities is a Passive Foreign Investment Company (“PFIC”) within the meaning of Section 1297 of the Internal Revenue Code of 1986, as amended (the “Code”).
Appears in 11 contracts
Samples: Underwriting Agreement, Underwriting Agreement, Underwriting Agreement (Teekay Offshore Partners L.P.)
Passive Foreign Investment Company. To the best knowledge of the Teekay Parties, after consultation with United States federal income tax counselCompany, none of the Teekay Entities is a Passive Foreign Investment Company (“PFIC”) within the meaning of Section 1297 of the Internal Revenue Code of 1986, as amended (the “Code”).
Appears in 4 contracts
Samples: Equity Distribution Agreement (Teekay Corp), Equity Distribution Agreement (Teekay Corp), Purchase Agreement (Teekay Corp)
Passive Foreign Investment Company. To the best knowledge of the Teekay Parties, after consultation with United States federal income tax counsel, none of the Teekay Entities that have or is generating income is a Passive Foreign Investment Company (“PFIC”) within the meaning of Section 1297 of the Internal Revenue Code of 1986, as amended (the “Code”).
Appears in 2 contracts
Samples: Underwriting Agreement (Teekay LNG Partners L.P.), Underwriting Agreement (Teekay LNG Partners L.P.)
Passive Foreign Investment Company. To the best knowledge of the Teekay Parties, after consultation with United States federal income tax counsel, none of the Teekay Entities that have or is generating income is a Passive Foreign Investment Company (“PFIC”) within the meaning of Section 1297 of the Internal Revenue Code of 1986, as amended (the “Code”).
Appears in 2 contracts
Samples: Underwriting Agreement (Teekay LNG Partners L.P.), Underwriting Agreement (Teekay LNG Partners L.P.)
Passive Foreign Investment Company. To the best knowledge of the Teekay Parties, after consultation with United States federal income tax counselCompany and the Guarantors, none of the Teekay Entities is a Passive Foreign Investment Company (“PFIC”) within the meaning of Section 1297 of the Internal Revenue Code of 1986, as amended (the “Code”).
Appears in 2 contracts
Samples: Purchase Agreement, Purchase Agreement (Teekay Corp)
Passive Foreign Investment Company. To the best knowledge of the Teekay Parties, after consultation with United States federal income tax counsel, none of the Teekay Entities that has generated or is generating income is a Passive Foreign Investment Company (“PFIC”) within the meaning of Section 1297 of the Internal Revenue Code of 1986, as amended (the “Code”).
Appears in 2 contracts
Samples: Underwriting Agreement (Teekay LNG Partners L.P.), Underwriting Agreement (Teekay LNG Partners L.P.)
Passive Foreign Investment Company. To the best knowledge of the Teekay Parties, after consultation with United States federal income tax counsel, none of the Teekay Entities is a Passive Foreign Investment Company (“PFIC”) within the meaning of Section 1297 of the Internal Revenue Code of 1986, as amended (the “Code”).
Appears in 1 contract
Samples: Underwriting Agreement (Teekay Offshore Partners L.P.)
Passive Foreign Investment Company. To the best knowledge of the Teekay Parties, after consultation with United States federal income tax counsel, none of the Teekay Entities is a Passive Foreign Investment Company (“PFIC”) within the meaning of Section 1297 of the Internal Revenue Code of 1986, as amended (the “Code”).
Appears in 1 contract
Samples: Underwriting Agreement (Teekay Offshore Partners L.P.)
Passive Foreign Investment Company. To the best knowledge of the Teekay Parties, after consultation with United States federal income tax counsel, none of the Teekay Entities that has generated or is generating income is a Passive Foreign Investment Company (“PFIC”) within the meaning of Section 1297 of the Internal Revenue Code of 1986, as amended (the “Code”).
Appears in 1 contract
Passive Foreign Investment Company. To the best knowledge of the Teekay Parties, after consultation with United States federal income tax counselPartnership, none of the Teekay Entities is a Passive Foreign Investment Company (“PFIC”) within the meaning of Section 1297 of the Internal Revenue Code of 1986, as amended (the “Code”).
Appears in 1 contract
Samples: Equity Distribution Agreement (Teekay Offshore Partners L.P.)
Passive Foreign Investment Company. To the best knowledge of the Teekay Parties, after consultation with United States federal income tax counsel, none of the Teekay Entities that have or is generating income is a Passive Foreign Investment Company (“PFIC”) within the meaning of Section 1297 of the Internal Revenue Code of 1986, as amended (the “Code”).
Appears in 1 contract
