New CFC definition

New CFC as defined in the definition of “IP Reorganization”.
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New CFC means Countrywide Financial Corporation after the Merger, including all of it past and present direct and indirect subsidiaries.
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Examples of New CFC in a sentence

  • The applicable percentage is reduced by 10 percentage points for each subsequent taxable year of the new controlled foreign corporation employer that ends after the date this document is published as a final regulation in the Federal Register.(iv) New CFC employer.

  • Maintain, at all times, an ownership structure such that (a) New CFC is wholly owned by U.S. Newco, Wholly Owned Subsidiary Guarantors or the Parent Borrower, (b) the New CFC Subsidiaries are wholly owned by New CFC or other New CFC Subsidiaries and (c) U.S. Newco is wholly owned by one or more Wholly Owned Subsidiary Guarantors or the Parent Borrower.

  • The main limitations of the empirical approach are: • The empirical approaches make it impossible to check whether they will obey basic laws of physics, such as conservation laws; • The strength parameters in RMR are not based on site- specific failure criterion (Xxxx-Coulomb) that may or may not meet site-specific rock conditions.

  • The New CFC legislation affects United Kingdom resident companies which are deemed to be interested (whether directly or indirectly) in at least 25 per cent.

  • Maintain, at all times, an ownership structure such that (a) New CFC is wholly owned by U.S. Newco, Wholly Owned Subsidiary Guarantors or the Borrower, (b) the New CFC Subsidiaries are wholly owned by New CFC or other New CFC Subsidiaries and (b) U.S. Newco is wholly owned by one or more Wholly Owned Subsidiary Guarantors or the Borrower.

  • See also Lee UK Finance Bill Introduces New CFC Rules http://www.tax- news.com/archive/story/UK_Finance_Bill_Includes_New_CFC_Rules_xxxx26909.html# accessed on 05 November 2009.In a survey conducted on behalf of KPMG [in 2006], two-thirds of respondents said that UK tax rules had hindered cross-border investment for their groups.

  • Jesper Barenfeld, 'Sweden’s New CFC Regime after Cadbury Schweppes – Comments and Analysis' (2008) 62 B.F.I.T. 7, 295.

  • Because the article is “produced” in the U.K., New C.F.C. 1 does not have foreign base company sales income.

  • If the software is developed by New C.F.C. 1 in the U.K. and sold as a shrink-wrap product to New C.F.C. 2 for distribution in Australia, no Subpart F Income arises in either country because the software is considered to be a copyrighted article.

Related to New CFC

  • New Company has the meaning given to it in Clause 21.3 of the Trust Deed;

  • Reorganized Company means the domestic stock company into which a mutual company has been converted, converted and merged, or converted and consolidated.

  • Newco has the meaning set forth in the first paragraph of this Agreement.

  • Participating Corporation means any Parent, Subsidiary or Affiliate that the Committee designates from time to time as eligible to participate in this Plan. For purposes of the Section 423 Component, only the Parent and Subsidiaries may be Participating Corporations, provided, however, that at any given time a Parent or Subsidiary that is a Participating Corporation under the Section 423 Component shall not be a Participating Corporation under the Non-Section 423 Component. The Committee may provide that any Participating Corporation shall only be eligible to participate in the Non-Section 423 Component.

  • Acquirer means a business organization, financial institution, or an agent of a business organization or financial institution that has authority from an organization that operates or licenses a credit card system to authorize merchants to accept, transmit, or process payment by credit card through the credit card system for money, goods or services, or anything else of value.

  • Initial Merger Consideration has the meaning set forth in Section 2.2(a).

  • VEBA means a voluntary employees' beneficiary association under IRC Section 501(c)(9).

  • New entrant means a teacher who is not a present teacher.

  • Transferee Company means any company or body corporate established in the Islands or in any other jurisdiction.

  • Reorganized Parent means, Core Scientific, Inc., a Delaware corporation, on and after the Effective Date.

  • Acquiring Corporation means (i) the continuing or surviving corporation of a consolidation or merger with Issuer (if other than Issuer), (ii) Issuer in a merger in which Issuer is the continuing or surviving person, and (iii) the transferee of all or substantially all of Issuer's assets.

  • Rollover Unit holder shall be defined as set forth in Section 5.05, herein."

  • SpinCo shall have the meaning set forth in the Preamble.

  • New Parent shall have the meaning assigned to such term in the definition of the term “Change in Control”.

  • ACCO means the person delegated authority by the Commissioner to organize and supervise the procurement activity of subordinate agency staff in conjunction with the CCPO, or his/her duly authorized representative. All written notices or communications to the ACCO shall be sent, as specified, to 00 Xxxxx Xxxxxx, 0xx Xxxxx, Xxx Xxxx, Xxx Xxxx 00000 (“Office of the ACCO”).

  • Eligible Holder means a Limited Partner whose (a) federal income tax status would not, in the determination of the General Partner, have the material adverse effect described in Section 4.9(a)(i) or (b) nationality, citizenship or other related status would not, in the determination of the General Partner, create a substantial risk of cancellation or forfeiture as described in Section 4.9(a)(ii).

  • Participating Stockholder means a “Participating Stockholder” under the HBB Stockholders’ Agreement, HY Stockholders’ Agreement and NACCO Stockholders’ Agreement, to the extent the Partnership owns HBB Class B Shares, HY Class B Shares or NACCO Class B Shares. A Partner shall cease to be a Participating Stockholder under this Agreement and shall be deemed to be a Former Partner immediately prior to any event or lapse of time that causes such Partner to no longer be a “Participating Stockholder” under such applicable stockholders’ agreements.

  • Participating Subsidiary means a Subsidiary which has been designated by the Administrator as covered by the Plan.

  • Effective FTR Holder means:

  • Eligible Holders has the meaning set forth in Section 2.01(a).

  • Surviving General Partner has the meaning set forth in Section 7.01(d) hereof.

  • Base Merger Consideration means $1,200,000,000.

  • RemainCo shall have the meaning set forth in the Preamble.

  • CPF means the Central Provident Fund;

  • Qualified Stockholder means: (a) the record holder of a share of Class B Common Stock as of the IPO Date; (b) the initial registered holder of any shares of Class B Common Stock that are originally issued by the Corporation after the IPO Date pursuant to the exercise or conversion of any Option or Convertible Security that, in each case, was outstanding as of the IPO Date; (c) each natural person who, prior to the IPO Date, Transferred shares of capital stock of the Corporation to a Permitted Entity that is or becomes a Qualified Stockholder; (d) each natural person who Transferred shares of, or equity awards for, Class B Common Stock (including any Option exercisable or Convertible Security exchangeable for or convertible into shares of Class B Common Stock) to a Permitted Entity that is or becomes a Qualified Stockholder; and (e) a Permitted Transferee.

  • Acquiring Company means a person who obtains Control of the Company;