Examples of Code Section 1297 in a sentence
In part, these projections are based upon expanding known resources either currently in advanced exploration, feasibility or production.
The Company is not and has never been a “personal holding company” (within the meaning of Code Section 542), a shareholder in a “controlled foreign corporation” (within the meaning of Code Section 957), in a “foreign personal holding company” (within the meaning of Code Section 552), or in a “passive foreign investment company” (within the meaning of Code Section 1297), or an owner in any entity treated as a partnership or disregarded entity for federal income Tax purposes.
None of the Acquired Companies is or has ever been a “personal holding company” (within the meaning of Code Section 542), or a shareholder in a “controlled foreign corporation” (within the meaning of Code Section 957), a “foreign personal holding company” (within the meaning of Xxx Section 552), or a “passive foreign investment company” (within the meaning of Code Section 1297).
Neither OCW nor any of its Subsidiaries has ever owned an interest in, (i) a “passive foreign investment company” within the meaning of Code Section 1297, or (ii) a “controlled foreign corporation” within the meaning of Code Section 957.
The Company is not and has never been a “personal holding company ” (within the meaning of Code Section 542), a shareholder in a “controlled foreign corporation ” (within the meaning of Code Section 957), in a 7/3393869.1 - 27 - “foreign personal holding company ” (within the meaning of Code Section 552), or in a “passive foreign investment company ” (within the meaning of Code Section 1297), or an owner in any entity treated as a partnership or disregarded entity for federal income Tax purposes.
The Partnership was not a “passive foreign investment company” (“PFIC”) as defined in Title 26 U.S. Code Section 1297 for its most recently completed taxable year and it does not expect to be a PFIC for the foreseeable future.
The Company was not a “passive foreign investment company” (“PFIC”) as defined in Title 26 U.S. Code Section 1297 for its most recently completed taxable year and does not expect to be a PFIC for the foreseeable future.
The Acquired Companies are not nor have they ever been a “personal holding company” (within the meaning of Code Section 542), a shareholder in a “controlled foreign corporation” (within the meaning of Code Section 957), a “foreign personal holding company” (within the meaning of Code Section 552), a “passive foreign investment company” (within the meaning of Code Section 1297), or a United States Real Property Holding Corporation (within the meaning of Code Section 897).
The Company is not and has never been a “personal holding company” (within the meaning of Code Section 542), a shareholder in a “controlled foreign corporation” (within the meaning of Code Section 957), in a “foreign personal holding company” (within the meaning of Code Section 552), or in a “passive foreign investment company” (within the meaning of Code Section 1297), or an owner in any entity treated as a partnership or disregarded entity for federal income tax purposes.
The Company (A) is not and has not been a ‘‘controlled foreign corporation’’ as defined in Code Section 957, (B) is not and has not been a “passive foreign investment company” within the meaning of Code Section 1297, and (C) does not have a permanent establishment (within the meaning of an applicable Tax treaty) or otherwise has an office or fixed place of business in a country other than the United States.