Disregarded Subsidiary definition

Disregarded Subsidiary means any Disregarded Entity that is held by the Company directly or indirectly through other Disregarded Entities.
Disregarded Subsidiary any Subsidiary that is disregarded as an entity separate from its sole owner under Treasury Regulation Sections 301, 7701-2(c)(2) or -3(b).
Disregarded Subsidiary means any Subsidiary that has no material assets other than the Capital Stock and/or Indebtedness of one or more Foreign Subsidiaries that are “controlled foreign corporations” (as defined in Section 957(a) of the Code) or one or more Disregarded Subsidiaries, IP Rights related to such Foreign Subsidiaries or Disregarded Subsidiaries, Cash or Cash Equivalents and other incidental assets related thereto.

Examples of Disregarded Subsidiary in a sentence

  • All Property Taxes levied (and refunds received) with respect to the Purchased Assets or the assets of any Disregarded Subsidiary Company for the Straddle Tax Period, and all contingent expenses paid to consultants for appealing such Property Taxes, shall be apportioned between Buyer and Seller based on the number of days of such Straddle Tax Period included in the Pre-Closing Tax Period and the number of days of such Straddle Tax Period included in the Post-Closing Tax Period.

  • For avoidance of doubt, the Covered Tax Liability of the Company for any taxable period shall be determined by including each Company Disregarded Subsidiary’s distributive share of the LLC’s taxable income (including any items of income, gain, loss or deduction allocated to such Company Disregarded Subsidiary under principles of Code Section 704(c)) for such taxable period.

  • Each Disregarded Subsidiary (other than Casino Computer Programming, Inc., an Indiana corporation ("CCPI")) has been "disregarded as an entity separate from its owner" within the meaning of Treasury Regulation Section 301.7701-3(b)(ii) for federal Income Tax purposes at all times since its acquisition by the Company.

  • Each Disregarded Subsidiary (other than Casino Computer Programming, Inc., an Indiana corporation (“CCPI”)) has been “disregarded as an entity separate from its owner” within the meaning of Treasury Regulation Section 301.7701-3(b)(ii) for federal Income Tax purposes at all times since its acquisition by the Company.


More Definitions of Disregarded Subsidiary

Disregarded Subsidiary means a Subsidiary of Crown Holdings that is disregarded as an entity separate from its owner for U.S. federal income tax purposes and that has no material assets other than Capital Stock of one or more Non-U.S. Subsidiaries that are CFCs.
Disregarded Subsidiary means any Subsidiary that is not organized as a corporation and for federal income tax purposes has only a single owner.
Disregarded Subsidiary shall have the meaning set forth in Section 1.10.
Disregarded Subsidiary means a Company Subsidiary that is treated as a disregarded entity for U.S. federal income Tax purposes.
Disregarded Subsidiary means any Subsidiary (other than any Subsidiary (x) owning any fee interest in real property or (y) that owns or operates a casino) that, as of any date of determination, does not have, together with its Subsidiaries, (i) assets with a value in excess of 1.5% of Consolidated Total Assets and (ii) did not, for the four fiscal quarter period ending on the last day of such fiscal quarter for which financial statements are available, have revenues or Consolidated EBITDA exceeding 1.5% of the total revenues or Consolidated EBITDA of the Borrower and its Subsidiaries. The aggregate amount of assets, revenues or Consolidated EBITDA of all such Disregarded Subsidiaries subject to an event described in clause (h), (i) or (j) of Article VII cannot exceed 5.0% of Consolidated Total Assets, revenues or Consolidated EBITDA. If a Disregarded Subsidiary becomes subject to an event described in clause (h), (i) or (j) of Article VII, then neither the Borrower nor any Subsidiary shall thereafter make any Investment in or to such Disregarded Subsidiary.
Disregarded Subsidiary means ACM Insurance.
Disregarded Subsidiary means a Subsidiary of Crown Holdings that is disregarded as an entity separate from its owner for