U.S. Limitations. The Foreign Cross-Guarantee shall not require any Foreign Domiciled Loan Party (that is a “controlled foreign corporation” within the meaning of Section 957 of the Code) to guarantee any Secured Obligations of any other Foreign Domiciled Loan Party that is disregarded as an entity separate from any U.S. Subsidiary for U.S. federal income tax purposes.
Appears in 2 contracts
Sources: Loan, Security and Guarantee Agreement (MRC Global Inc.), Loan, Security and Guarantee Agreement (MRC Global Inc.)
U.S. Limitations. The To the extent that an adverse Tax consequence would result, the Foreign Cross-Guarantee shall not require any Foreign Domiciled Loan Party (that is a “controlled foreign corporation” within the meaning of Section 957 of the Code) or any Subsidiary of any such Foreign Domiciled Loan Party to guarantee any Secured Obligations of any other Foreign Domiciled Loan Party that is disregarded as an entity separate from any U.S. Subsidiary for U.S. federal income tax Tax purposes.
Appears in 1 contract
Sources: Loan, Security and Guarantee Agreement (Kraton Performance Polymers, Inc.)
U.S. Limitations. The To the extent that an adverse tax consequence would result, the Foreign Cross-Guarantee shall not require any Foreign Domiciled Loan Party (that is a “controlled foreign corporation” within the meaning of Section 957 of the Code) or any Subsidiary of any such Foreign Domiciled Loan Party to guarantee any Secured Obligations of any other Foreign Domiciled Loan Party that is disregarded as an entity separate from any U.S. Subsidiary for U.S. federal income tax purposes.
Appears in 1 contract
Sources: Loan, Security and Guarantee Agreement (Edgen Group Inc.)