Controlled Foreign Corporation definition
Controlled Foreign Corporation means “controlled foreign corporation” as defined in the Internal Revenue Code.
Controlled Foreign Corporation means a “controlled foreign corporation” as defined in the 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.
Examples of Controlled Foreign Corporation in a sentence
Any change in the accounting policies of a JV Group Company other than as required by law or in order to address Controlled Foreign Corporation issues relating to any of the New Investor’s shareholders (and in particular, but without limitation, ▇▇▇▇▇▇▇▇▇▇▇▇ ▇▇▇▇▇▇▇▇▇▇▇▇▇▇▇▇▇).
These principles also apply with respect to any entity that becomes a United States Person and/or a Controlled Foreign Corporation, CFC Holding Company or subsidiary of a Controlled Foreign Corporation or CFC Holding Company following any guarantee or pledge of assets or shares.
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 that is a “controlled foreign corporation” as defined in Section 957(a) of the 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 (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 United States Internal Revenue Code of 1986, as amended from time to time.
Controlled Foreign Corporation means “controlled foreign corporation” as defined in the IRC.
Controlled Foreign Corporation means a “controlled foreign corporation” as defined in Section 957(a) of the 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 Equity Interests and/or Indebtedness 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.