GILTI Inclusion definition

GILTI Inclusion means any amounts required to be included in gross income of the Company or any of its Subsidiaries pursuant to Section 951A of the Code if the taxable year of the Company or such Subsidiary, as applicable, were deemed to end on the date after the Closing Date.
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GILTI Inclusion means any amounts required to be included in the gross income of any member of the Seller Consolidated Group pursuant to Section 951A of the Code (taking into account the applicability of Section 245A of the Code) if the taxable year of any such member, as applicable, were deemed to end on the Closing Date.
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GILTI Inclusion means any amounts required to be included in gross income of any Divested Company pursuant to Section 951A of the Code if the taxable year of the Divested Company were deemed to end on the date after the Closing Date.
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Examples of GILTI Inclusion in a sentence

  • GILTI Inclusion AmountsProposed §1.960-2(c) provides that the amount of the tested foreign income taxes that a United States shareholder is deemed to pay under section 960(d) is computed with respect to the income of the CFC in each tested income group within a section 904 category.

  • In theory, this should mean GILTI Inclusion from any CFC paying more than 13.125% tax in the foreign country would be effectively eliminated using the IRC §250 GILTI deduction and FTCs. As any international practitioner has experienced, this is rarely the case in practice due to IRC §250 deduction and IRC §904 FTC limitations.

  • GILTI Inclusion Amounts Proposed § 1.960–2(c) provides thatthe amount of the tested foreign income taxes that a United States shareholder is deemed to pay under section 960(d) is computed with respect to the income ofthe CFC in each tested income group within a section 904 category.

  • The people in the current scenario having faith in the Print media believes what is published in it is truth, therefore, while publishing any news in the Newspaper, it is expected that it should be published with utmost care and caution and sensibly after scrutinizing its genuineness and truthfulness on the basis of some material.

  • Due to these limitations, it is possible that even GILTI Inclusion from a CFC with a local tax rate far exceeding 13.125% would still result in an increase in tax liability.

  • U.S. Shareholder will have no NDTIR or DTIR because its pro rata share of the QBAI of its Tested Income CFC (CFC2) is zero.Therefore, U.S. Shareholder will have a GILTI Inclusion Amount of $8x.

  • Without clarification, there is a concern that if the transaction was found to be part of a plan a principal purpose of which is to reduce X’s Subpart F or GILTI Inclusion with respect to Y, the sale would be disregarded for purposes of determining Subpart F Income or GILTI.

  • While it may not impact the current year taxable income, failing to make the election may leave money on the table in the form of missed NOLs.Example 2:US Holdco, a United States C Corporation, has a taxable loss before GILTI of $1,000,000 and GILTI Inclusion from its investment in CFC 1 of $1,000,000.

Related to GILTI Inclusion

  • Reference evapotranspiration or “ETo” means a standard measurement of environmental parameters which affect the water use of plants. ETo is given expressed in inches per day, month, or year as represented in Appendix C of these Guidelines, and is an estimate of the evapotranspiration of a large field of four to seven-inch tall, cool-season grass that is well watered. Reference evapotranspiration is used as the basis of determining the Maximum Applied Water Allowances.

  • Inclusionary development means a development containing both affordable units and market rate units. This term includes, but is not necessarily limited to: new construction, the conversion of a non-residential structure to residential and the creation of new affordable units through the reconstruction of a vacant residential structure.

  • Scheduled Black-Out Period means the period from and including the last day of a fiscal quarter of the Company to and including the business day after the day on which the Company publicly releases its earnings for such fiscal quarter.

  • Massive Multiauthor Collaboration Site (or “MMC Site”) means any World Wide Web server that publishes copyrightable works and also provides prominent facilities for anybody to edit those works. A public wiki that anybody can edit is an example of such a server. A “Massive Multiauthor Collaboration” (or “MMC”) contained in the site means any set of copyrightable works thus published on the MMC site.

  • Tariff period means the period for which tariff is to be determined by the Commission on the basis of norms specified under these Regulations;

  • Look-back Period means, with respect to any Employment Violation by Grantee, the period beginning on the date which is 12 months prior to the date of such Employment Violation by Grantee and ending on the date of computation of the Recapture Amount with respect to such Employment Violation.

  • Core Earnings means, with respect to any Person for any period, net income determined in accordance with GAAP of such Person and its consolidated subsidiaries and excluding (but only to the extent included in determining net income for such period) (i) non-cash equity compensation expense, (ii) the expenses incurred in connection with the formation of the Sponsor and the offering in connection therewith, including the initial underwriting discounts and commissions, (iii) acquisition costs from successful acquisitions (other than acquisitions made in the ordinary course of business), (iv) real property depreciation and amortization, (v) any unrealized gains or losses or other similar non-cash items that are included in net income for the current quarter, regardless of whether such items are included in other comprehensive income or loss, (vi) extraordinary or non-recurring gains or losses and (vii) one-time expenses, charges or gains relating to changes in GAAP; provided that Core Earnings shall, solely with respect to the Core Earnings attributable to any Non Wholly-Owned Consolidated Affiliate, only include the Consolidated Group Pro Rata Share of such attributable amount.

  • Black-Out Period means any “black-out” or similar period under the Corporation’s policies covering trading in the Corporation’s securities to which the applicable Redeeming Member is subject (or will be subject at such time as it owns Class A Common Stock), which period restricts the ability of such Redeeming Member to immediately resell shares of Class A Common Stock to be delivered to such Redeeming Member in connection with a Share Settlement.

  • Day fine means a fine imposed by the sentencing court that

  • Reference Year shall have the meaning given it in the Summary.

  • Elimination Period means the period of 6 months beginning on the date You become Disabled.

  • Off-Peak Period means the period during which the demand on an electric utility system is not at or near its maximum. For the purpose of this section, the off-peak period includes all hours that are not in the peak period.

  • Source-image receptor distance means the distance from the source to the center of the input surface of the image receptor.

  • HICP Daily Inflation Reference Index means (A) in relation to the first calendar day of any given month, the HICP Monthly Reference Index of the third month preceding such month, and (B) in relation to a calendar day (D) (other than the first calendar day) in any given month (M), the linear interpolation of the HICP Monthly Reference Index pertaining respectively to the third month preceding such month (M - 3) and the second month preceding such month (M - 2) calculated in accordance with the following formula:

  • Base Period Income is an amount equal to Executive's "annualized includable compensation" for the "base period" as defined in Sections 280G(d)(1) and (2) of the Code and the regulations adopted thereunder. Generally, Executive's "annualized includable compensation" is the average of Executive's annual taxable income from Company for the "base period," which is the five calendar years prior to the year in which the Change of Control occurs. These concepts are complicated and technical and all of the rules set forth in the applicable regulations apply for purposes of this Agreement.

  • Reconstructive breast surgery means surgery performed as a result of a mastectomy to reestablish symmetry between the two breasts and includes augmentation mammoplasty, reductive mammoplasty, and mastopexy.

  • CPI Daily Inflation Reference Index means (A) in relation to the first day of any given month, the CPI Monthly Reference Index of the third month preceding such month, and (B) in relation to a day (D) (other than the first day) in any given month (M), the linear interpolation of the CPI Monthly Reference Index pertaining respectively to the third month preceding such month (M - 3) and the second month preceding such month (M - 2) calculated in accordance with the following formula:

  • SONIA Compounded IndexStart means, with respect to an Interest Accrual Period, the SONIA Compounded Index determined in relation to the day falling the Relevant Number of London Banking Days prior to the first day of such Interest Accrual Period; and

  • MINORITY BUSINESS ENTERPRISE (MBE means an individual, partnership, corporation or joint venture of any kind that is owned and controlled by U. S. Citizens and residents of Ohio, who are and have held themselves out as members of the following socially and economically disadvantaged groups: Blacks, American Indians, Hispanics and Asians. Only businesses certified by the State of Ohio Equal Opportunity Division in accordance with Section 123.151 of the Ohio Revised Code shall be recognized as being MBE certified within the purpose of this invitation.

  • total earnings means all of the dentist's gross earnings from the practice of dentistry by him in person, and "NHS earnings" means the dentist's gross earnings from the provision by him in person of general dental services under the National Health Service (Scotland) Act 1978, as amended, including where the dentist's name is included in sub-part A of the first part, or Part A prior to 2 July 2010, of two or more dental lists in Scotland, but neither his total earnings nor his NHS earnings shall be taken to include any remuneration by way of salary;

  • Cooling Off Period means the duration of time counted from the date when the direct seller and the direct selling entity enter into an agreement and ending with the date on which the contract is to be performed and within which direct seller may repudiate the agreement without being subject to penalty for breach of contract.

  • PEG means public, educational and governmental.

  • Minor source baseline date means the earliest date after the trigger date on which a major stationary source or a major modification subject to 40 CFR 52.21 or to regulations approved pursuant to 40 CFR 51.166 submits a complete application under the relevant regulations. The trigger date is:

  • Comparator Group is defined as the following nine U.S. based carriers including, AirTran Airways, Inc., Alaska Air Group, Inc., AMR Corporation, Continental Airlines, Inc., Delta Air Lines Inc., JetBlue Airways Corporation, Southwest Airlines Co., US Airways Group, Inc. and UAL Corporation.

  • Classroom exclusion means the exclusion of a student from a classroom or instructional or activity area for behavioral violations, subject to the requirements of WAC 392-400-330 and 392-400-335. Classroom exclusion does not include action that results in missed instruction for a brief duration when:

  • Opt-Out Period means the period that begins the day after the earliest date on which the Notice is first distributed, and that ends no later than 30 days before the Final Approval Hearing. The deadline for the Opt-Out Period shall be specified in the Notice.