Deemed Dividend definition

Deemed Dividend means, with respect to any Foreign Subsidiary, such Foreign Subsidiary’s accumulated and undistributed earnings and profits being deemed to be repatriated to the Company or the applicable parent Domestic Subsidiary under Section 956 of the Code.
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Deemed Dividend means, with respect to any Foreign Subsidiary, such Foreign Subsidiary's accumulated and undistributed earnings and profits being deemed to be repatriated to the Borrower or the applicable parent Domestic Subsidiary under Section 956 of the Code and the effect of such repatriation causing materially adverse tax consequences to the Borrower or such parent Domestic Subsidiary, in each case as determined by the Borrower in its commercially reasonable judgment acting in good faith and in consultation with its legal and tax advisors.
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Deemed Dividend has the meaning set forth in Section 17(f)(ii).
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Examples of Deemed Dividend in a sentence

  • Notwithstanding the foregoing, the Borrower shall not be required to furnish any such pledges, guaranties, security interests or related documents or instruments with respect to a Foreign Subsidiary to the extent that such actions would (x) violate the laws of the jurisdiction of formation of such Foreign Subsidiary or (y) create or result in a Deemed Dividend Problem.

  • Enter gain or loss on line 15f of Part V.E Deemed Dividend Election.

  • Enter gain on line 15f of Part V.G Deemed Dividend Election With Respect to a Section 1297(e) PFIC.

  • If the excess distribution is greater than zero, also complete line 16, Part V.H Deemed Dividend Election With Respect to a Former PFIC.

  • Notwithstanding the foregoing, no Foreign Subsidiary shall be required to execute and deliver the Guaranty Agreement (or supplement thereto) or such other guaranty agreement if such execution and delivery would cause a Deemed Dividend Problem or a Financial Assistance Problem with respect to such Foreign Subsidiary and, in lieu thereof, the Borrower and the relevant Restricted Subsidiaries shall provide the pledge agreements required under this Section 5.10 or Section 5.11.

  • Complete Part II, lines 1, 2, and 4, and Part IV.C Late Deemed Dividend Election With Respect to a Section 1297(e) PFIC.

  • Post Amendment, It can be inferred that, Deemed Dividend u/s 2(22)(e) is chargeable to DDT @ 30% in hands of closely held company.

  • Notwithstanding the foregoing, no Foreign Subsidiary shall be required to execute and deliver the Multiparty Guaranty (or supplement thereto) or such other guarantee agreement if such execution and delivery would cause a Deemed Dividend Problem or a Financial Assistance Problem with respect to such Foreign Subsidiary and, in lieu thereof, the Company and the relevant Subsidiaries shall provide the pledge agreements required under this Section 9.7 or Section 9.8.

  • Any reuse without written verification or adaptation by CONSULTANT for the specific purposes intended will be at OWNER’s sole risk and without liability or legal exposure to CONSULTANT; and OWNER shall indemnify and hold harmless CONSULTANT from all claims, damages, losses and expenses including attorneys’ fees arising out of or resulting therefrom.

  • Notwithstanding the foregoing, no action or omission contemplated by this Section 10.14 shall be permitted or required to the extent such action or omission would cause a Deemed Dividend Problem.


More Definitions of Deemed Dividend

Deemed Dividend means, for each cash dividend declared by DRDGOLD during the Reference period, an amount deemed to be paid to the Seller on the same date that the relevant dividend is paid by DRDGOLD in an amount, for each relevant dividend payment, equal to the total value in Rands of all dividends declared and paid divided by the sum of (i) the total number of DRDGOLD Shares in respect of which dividends are paid and (ii) a further 35,000,000 DRDGOLD Shares and further multiplying this resultant amount by the number of Consideration Shares;
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Deemed Dividend means, with respect to each Stock Unit held by a Participant, a notional amount credited to the Participant’s Account equal to the amount in cash or value in Stock or other property from dividends paid with respect to one share of Stock.
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Deemed Dividend has the meaning set forth in Exhibit G.
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Deemed Dividend means any income generated under Section 951 ----------------- of the Code.
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Related to Deemed Dividend

  • Accumulated Dividends means, with respect to any share of Preferred Stock, as of any date, the aggregate accumulated and unpaid dividends on such share from the Issue Date until the most recent Dividend Payment Date on or prior to such date. There shall be no Accumulated Dividends with respect to any share of Preferred Stock prior to the first Dividend Payment Date.

  • Preferred Dividends means, with respect to any Person, dividends or other distributions which are payable to holders of any Equity Interests in such Person which entitle the holders of such Equity Interests to be paid on a preferred basis prior to dividends or other distributions to the holders of other types of Equity Interests in such Person.

  • Accrued Dividends means, with respect to any share of Preferred Stock, as of any date, the accrued and unpaid dividends on such share from and including the most recent Dividend Payment Date (or the Issue Date, if such date is prior to the first Dividend Payment Date) to but not including such date.

  • Ex-Dividend Date means the first date on which shares of the Common Stock trade on the applicable exchange or in the applicable market, regular way, without the right to receive the issuance, dividend or distribution in question, from the Company or, if applicable, from the seller of Common Stock on such exchange or market (in the form of due bills or otherwise) as determined by such exchange or market.

  • Dividend Payment Date means February 15, May 15, August 15 and November 15 of each year.

  • Dividend Payout Ratio means, at any date of determination, the ratio, expressed as a percentage, of (a) the sum of, without duplication, of all dividends paid by the Parent Guarantor on account of any common stock or preferred stock of the Parent Guarantor, except dividends payable solely in additional Equity Interests of the same class, to (b) Funds From Operations, in each case for the four consecutive fiscal quarters of the Parent Guarantor most recently ended.

  • Extraordinary Dividend means an amount per Share, the characterisation of which or portion thereof as an extraordinary dividend shall be determined by the Determination Agent.

  • Dividend Date means a date specified in the Issue Resolution on which a dividend in respect of that preference share is payable.

  • Dividend means any dividend (whether interim or final) resolved to be paid on Shares pursuant to the Articles.

  • Dividend Parity Stock means any class or series of stock of the Corporation that ranks on a parity with the Series E in the payment of current dividends, including the Series A, the Series B, the Series C and the Series D.

  • Special Dividend means any special or abnormal dividend or distribution in respect of securities (including a distribution of income or capital) and includes a dividend or distribution described by the entity declaring that dividend or distribution as:

  • Permitted Dividends means dividends or distributions made by the Company on its Class A Shares, and, without duplication, the Operating Partnerships to fund such dividends or distributions, annually in an aggregate amount equal to not less than 20% of the Company’s annual Distributable Earnings or more than 30% of Distributable Earnings; provided, that, if the minimum amount of dividends or distributions eligible to be made hereunder would be $1.00 or less per Class A Share, then up to $1.00 per Class A Share (subject to appropriate adjustment in the event of any equity dividend, equity split, combination or other similar recapitalization with respect to the Class A Shares after the Issuance Date).

  • Dividends shall have the meaning provided in Section 10.6.