Code Section 951 definition

Code Section 951 means 26 U.S.C. § 951 or any similar statute hereafter enacted having substantially the same purpose and effect as such Code Section.
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Code Section 951 means 26 U.S.C. § 951 or any similar statute hereafter enacted having substantially the same purpose and effect as such Code Section. “Code Section 951(a)” shall mean 26 U.S.C. § 951(a) or any similar statute hereafter enacted having substantially the same purpose and effect as such Code Section. “Code Section 951(b)” shall mean 26 U.S.C. § 951(b) or any similar statute hereafter enacted having substantially the same purpose and effect as such Code Section. “Code Section 957” shall mean 26 U.S.C. § 957 or any similar statute hereafter enacted having substantially the same purpose and effect as such Code Section. “Code Section 1291” shall mean 26 U.S.C. § 1291 or any similar statute hereafter enacted having substantially the same purpose and effect as such Code Section. “Code Section 1295” shall mean 26 U.S.C. § 1295 or any similar statute hereafter enacted having substantially the same purpose and effect as such Code Section. “Code Section 1297” shall mean 26 U.S.C. § 1297 or any similar statute hereafter enacted having substantially the same purpose and effect as such Code Section. Appendix A to Amended and Restated Shareholders’ Agreement
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Examples of Code Section 951 in a sentence

  • The Company further agrees to provide to the Accounting Firm and SOF all information and reasonable access to its books and records necessary or helpful to the Accounting Firm, as requested by such Accounting Firm or SOF, to carry out the Accounting Firm’s duties under this Section and otherwise for SOF to determine and comply with its reporting and tax payment obligations under Code Section 951.

  • The Company further agrees to provide to the Accounting Firm and SOF all information and reasonable access to its books and records necessary or helpful to the Accounting Firm, as requested by such Accounting Firm or SOF, to carry out the Accounting Firm's duties under this Section and otherwise for SOF to determine and comply with its reporting and tax payment obligations under Code Section 951.

  • A community college District whose county property tax receipts excluding ERAF (Education Revenue Augmentation Funds) exceed the amount of funding that would have been apportioned by the State for a specific Fiscal Year; also known as an Aexcess tax school entity@ pursuant to California Revenue and Taxation Code Section 95.1.

  • The Company shall use its reasonable best efforts to cause its Subsidiaries to avoid recognizing income that would be includible by the Company and its Members under Code Section 951; PROVIDED THAT the Company and its Subsidiaries shall be free to take actions which will result in income includible by the Company and its Members so long as the Company pays tax distributions to the Members with respect to such income under Section 3.1(b).

  • Notwithstanding the foregoing, all Taxes attributable to income includable under Code Section 951 with respect to the operations and activities of the Company’s foreign Subsidiaries for the Pre-Closing Tax Period included in the last Straddle Period beginning prior to the Closing Date shall be included in the portion of the Straddle Period ending on the Closing Date, even if such income is includable after the Closing Date.

  • Title 18, United States Code, Section 951; Title 22, United States Code, Sections 611–621; Title 50, United States Code, Sections 851–857.

  • The Company further agrees to provide to the Accounting Firm and SOF all information and reasonable access to its books and records necessary or helpful to the Execution Version Accounting Firm, as requested by such Accounting Firm or SOF, to carry out the Accounting Firm’s duties under this Section and otherwise for SOF to determine and comply with its reporting and tax payment obligations under Code Section 951.

  • For the further avoidance of doubt, any US federal taxable income realized by the Company and its Subsidiaries under Code Section 951 that results from, or to the extent is increased by, any action taken by the Buyer, the Company, or their respective Affiliates after the Closing shall be considered to occur in a taxable period that begins after the Closing Date for purposes of this Section 10.01(a) and Article VIII.

  • None of the Company and its Subsidiaries is a United States Shareholder (as defined in Code Section 951) of any controlled foreign corporation.

  • For purposes of Section 7.3(c), the Taxes payable by the Company or any of its Subsidiaries pursuant to Code Section 951 and attributable to the Pre-Closing Tax Period will deemed to be the amount that would have been payable if the taxable year of the applicable “controlled foreign corporation” had ended as of the close of the Closing Date.

Related to Code Section 951

  • Code Section 409A means Section 409A of the Code and all regulations issued thereunder and applicable guidance thereto.

  • the Code means the Pension Regulator’s Code of Practice No 14 governance and administration of public service pension schemes.

  • Code means the Internal Revenue Code of 1986, as amended.

  • IRC means the Internal Revenue Code of 1986, as amended.

  • Section 409A of the Code means the nonqualified deferred compensation rules under Section 409A of the Code and any applicable treasury regulations and other official guidance thereunder.

  • Treasury Regulation means the United States Treasury regulations promulgated under the Code.

  • Treasury Regulations means the regulations promulgated under the Code.

  • Section 409A means Section 409A of the Code and the regulations and other guidance promulgated thereunder.

  • Section 162(m) of the Code means the exception for performance-based compensation under Section 162(m) of the Code and any applicable treasury regulations thereunder.

  • Qualified employer means the federal government.

  • Taxable Wage Base means, with respect to any Plan Year, the contribution and benefit base under Section 230 of the Social Security Act at the beginning of such Plan Year.

  • Section 409A Limit means the lesser of two (2) times: (i) Executive’s annualized compensation based upon the annual rate of pay paid to Executive during the Company’s taxable year preceding the Company’s taxable year of Executive’s termination of employment as determined under Treasury Regulation 1.409A-1(b)(9)(iii)(A)(1) and any Internal Revenue Service guidance issued with respect thereto; or (ii) the maximum amount that may be taken into account under a qualified plan pursuant to Section 401(a)(17) of the Code for the year in which Executive’s employment is terminated.

  • Tax Code means the Internal Revenue Code of 1986, as amended.

  • Foreign Pension Plan means any plan, fund (including, without limitation, any superannuation fund) or other similar program established or maintained outside the United States of America by the Borrower or any one or more of its Subsidiaries primarily for the benefit of employees of the Borrower or such Subsidiaries residing outside the United States of America, which plan, fund or other similar program provides, or results in, retirement income, a deferral of income in contemplation of retirement or payments to be made upon termination of employment, and which plan is not subject to ERISA or the Code.

  • Safe Harbors has the meaning set forth in Section 11.3.C hereof.

  • Safe Harbor has the meaning set forth in Section 10.2(d).

  • Minimum Generation Emergency means an Emergency declared by the Office of the Interconnection in which the Office of the Interconnection anticipates requesting one or more generating resources to operate at or below Normal Minimum Generation, in order to manage, alleviate, or end the Emergency.

  • Cafeteria plan means a written plan under which all participants are employees, and the participants may choose among two or more benefits consisting of cash and qualified benefits.

  • Short-Term Deferral Period means the period ending on the later of the 15th day of the third month following the end of the Executive’s tax year in which the separation from service occurs and the 15th day of the third month following the end of the Company’s tax year in which the separation from service occurs; and

  • Section 280G means Section 280G of the Code and the Treasury regulations promulgated thereunder or any similar or successor provision.

  • Section 162(m means Section 162(m) of the Code.

  • Maximum Generation Emergency means an Emergency declared by the Office of the Interconnection to address either a generation or transmission emergency in which the Office of the Interconnection anticipates requesting one or more Generation Capacity Resources, or Non- Retail Behind The Meter Generation resources to operate at its maximum net or gross electrical power output, subject to the equipment stress limits for such Generation Capacity Resource or Non-Retail Behind The Meter resource in order to manage, alleviate, or end the Emergency.

  • Parachute Payment means a payment that is described in Code Section 280G(b)(2), determined in accordance with Code Section 280G and the regulations promulgated or proposed thereunder.

  • Basic health benefit plan means any plan offered to an individual, a small group,

  • Foreign Benefit Law means any applicable statute, law, ordinance, code, rule, regulation, order or decree of any foreign nation or any province, state, territory, protectorate or other political subdivision thereof regulating, relating to, or imposing liability or standards of conduct concerning, any Employee Benefit Plan.

  • Qualified employment position means a permanent full-time