Controlled Foreign Corporation definition

Controlled Foreign Corporation means “controlled foreign corporation” as defined in the Tax Code.

Controlled Foreign Corporation means any Subsidiary which is (i) a “controlled foreign corporation” (within the meaning of Section 957 of the Code), (ii) a subsidiary substantially all the assets of which consist of debt or equity in Subsidiaries described in clause (i) of this definition, or (iii) an entity treated as disregarded for U.S. federal income tax purposes that owns more than 65% of the voting stock of a Subsidiary described in clause (i) or (ii) of this definition.

Controlled Foreign Corporation means a controlled foreign corporation within the meaning of Section 957(a) of the Code.

Examples of Controlled Foreign Corporation in a sentence

• Voting stock of any Controlled Foreign Corporation in excess of 65% of the issued and outstanding voting stock of such Controlled Foreign Corporation shall not be included as a Portfolio Investment for purposes of calculating the Borrowing Base.

• ForU.S. income tax purposes, the Subsidiary is a Controlled Foreign Corporation (“CFC”) not subject to U.S. income taxes.

• These principles also apply with respect to any entity that becomes a United States Person and/or a Controlled Foreign Corporation following any guarantee.

• In no event shall PEWC Transfer any Shares Owned by PEWC to a United States organized or domiciled Affiliate if such Transfer results in, or is reasonably likely to result in, the Company being a Controlled Foreign Corporation; provided that in no event shall such Transfer be in an amount of Shares greater than 9.9% of the total outstanding Shares.

• Notwithstanding anything to the contrary herein, in no event will any of the outstanding voting stock of a Controlled Foreign Corporation, in excess of 65% of the voting power of all classes of capital stock of such Controlled Foreign Corporation entitled to vote, be pledged.

More Definitions of Controlled Foreign Corporation

Controlled Foreign Corporation means any foreign corporation if more than 50 percent of the total combined voting power of all classes of stock of such corporation entitled to vote, or the total value of the stock of such corporation, is owned, or is considered as owned, by “United States shareholders” on any day during the taxable year of such foreign corporation. The term a “United States shareholder” means, with respect to any foreign corporation, a United States person who owns, or is considered as owning, 10 percent or more of the total combined voting power of all classes of stock entitled to vote of such foreign corporation.

Controlled Foreign Corporation means any Subsidiary which is (i) a “controlled foreign corporation” (within the meaning of Section 957 of the Code), (ii) a Subsidiary substantially all the assets of which consist (directly or indirectly through one or more flow-through entities) of Equity Interests and/or indebtedness of one or more Subsidiaries described in clause (i) of this definition, or (iii) an entity treated as disregarded for U.S. federal income tax purposes and substantially all of the assets of which consist (directly or indirectly through one or more flow-through entities) of the Equity Interests and/or indebtedness of one or more Subsidiaries described in clause (i) or (ii) of this definition.

Controlled Foreign Corporation means "controlled foreign corporation" as defined in the Tax Code.

Controlled Foreign Corporation means “controlled foreign corporation” as defined in the United States Internal Revenue Code of 1986, as amended from time to time.

Controlled Foreign Corporation means “controlled foreign corporation” as defined in the Code.

Controlled Foreign Corporation means “controlled foreign corporation” as defined in the IRC.

Controlled Foreign Corporation has the meaning given to such term in Section 957 of the Code.