QEF Election definition

QEF Election has the meaning set forth in Section 6.7.

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QEF Election has the meaning ascribed to such term in Section 3.3(a).

QEF Election has the meaning ascribed to it in Section 8.3 hereof.

Examples of QEF Election in a sentence

• Upon request of any Purchaser any time and from time to time, the Company will either represent to such Purchaser that the Company is not a “passive foreign investment company” (“PFIC”) or promptly provide the information necessary for such Purchaser to make a Qualified Electing Fund (QEF) Election with respect to the Company and will cause each direct and indirect Subsidiary that the Company controls that is a PFIC to provide such information with respect to such Subsidiary.

• Upon request of any U.S. Purchaser at any time and from time to time, the Company will promptly provide the information necessary for such U.S. Purchaser to make a QEF Election with respect to the Company and will use reasonable best efforts to cause each direct and indirect subsidiary that the Company controls that is a PFIC to provide such information with respect to such Subsidiary.

• If the Company becomes a PFIC, upon request of Purchaser at any time and from time to time, the Company will promptly provide the information necessary for Purchaser to make a QEF Election with respect to the Company and will cause each direct and indirect subsidiary that the Company controls to provide such information to Purchaser with respect to such subsidiary.

• Such QEF Election or elections are, or will be, effective for all periods in which the Company is considered to own the stock to which the election relates.

• The procedure for making a QEF Election, and the U.S. federal income tax consequences of making a QEF Election, will depend on whether such QEF Election is timely.

More Definitions of QEF Election

QEF Election means a “qualified electing fund” election under Section 1295 of the Code.

QEF Election means an election made pursuant to section 1295(b) of the Code to cause the Company to be treated as a “qualified election fund” pursuant, to section 1292 to 1295 of the Code;

QEF Election means "qualified electing fund" as established in Code Section 1295.

QEF Election has the meaning ascribed to it in Section 10.9 of this Agreement.

QEF Election has the meaning given in clause 5.2;

QEF Election means an election made under Section 1295(b) of the Internal Revenue Code by a U.S. Person that is a direct or indirect shareholder of a PFIC to treat the PFIC as a qualified electing fund.

QEF Election means an election by a U.S. Holder to treat such U.S. Holder’s share of BREP’s interest in a PFIC as a “qualified electing fund”.