CFC Subsidiary means, with respect to any U.S. Subsidiary, a direct or indirect subsidiary of such U.S. Subsidiary that is a controlled foreign corporation within the meaning of Section 957 of the Code.
CFC Subsidiary means any Subsidiary of the Borrower that is organized under the laws of the United States or any state or district thereof and substantially all of the assets of which consist (directly, or indirectly through one or more disregarded entities) of Capital Stock of one or more Subsidiaries of the Borrower organized under the laws of a jurisdiction other than the United States or any state or district thereof.
CFC Subsidiary means each Subsidiary of a US Borrower that is incorporated or organised under the laws of any jurisdiction other than the United States or any state or territory thereof and is a “controlled foreign corporation” (within the meaning of Section 957 of the Code) and “FSHCO” means any entity, substantially all the assets of which consist of equity interests (or equity interests and indebtedness) of one or more CFC Subsidiaries or entities that are themselves FSHCOs.
Examples of CFC Subsidiary in a sentence
CFC shall duly perform all its obligations under the CFC Subsidiary Loan Agreement.
In accordance with government advice, all Hampshire Pension Services staff are continuing to work from home.
But, the above case posits that §1248 no longer applies after the transfer because CFC Subsidiary #1 loses its CFC status.
Depending on the results, any CFC Subsidiary Holding can either be retained as such or else liquidated into CFC Master Holding in a transaction that qualifies for nonrecognition of gain and loss under Section 332.
If a separate grouping of two or more CFCs was desirable, those could be contributed together to a separate CFC Subsidiary Holding.
More Definitions of CFC Subsidiary
CFC Subsidiary means any Subsidiary that is a “controlled foreign corporation” within the meaning of Section 957 of the Internal Revenue Code of 1986, as amended.
CFC Subsidiary means any Subsidiary that is a controlled foreign corporation for purposes of Section 957 of the Code.
CFC Subsidiary means any Subsidiary which is either (1) a Foreign Subsidiary Holding Company or (2) a Controlled Foreign Corporation or any Subsidiary thereof.
CFC Subsidiary shall have the meaning set forth in Section 3.1(b).
CFC Subsidiary means any Foreign Subsidiary that constitutes a controlled foreign corporation within the meaning of Section 957 of the Code to the extent the providing by such Foreign Subsidiary of a Guarantee of the Obligations of the US Borrower could reasonably be expected to result in adverse tax consequences to Holdings or any of its Subsidiaries.
CFC Subsidiary means any Restricted Subsidiary of ACCO that is a controlled foreign corporation for purposes of Section 957 of the Internal Revenue Code.
CFC Subsidiary means any Subsidiary of the Borrower that is: (a) a “controlled foreign corporation” within the meaning of Section 957 of the Code, (b) a “domestic corporation” or “domestic partnership” within the meaning of Section 7701(a)(30) of the Code that has no material assets other than equity interests in one or more Subsidiaries that are controlled foreign corporations within the meaning of Section 957 of the Code and that conduct no business other than holding such equity interests, and (c) disregarded as an entity separate from its owner under Treasury Regulations Section 301.7701-3 that has no material assets other than equity interests in one or more Subsidiaries described in parts (a) and (b) of this definition.