Subpart F Income definition

Subpart F Income means, collectively, (i) “subpart F income,” as defined in Section 952 of the Code and (ii) any investment in “United States property,” as defined in Section 956 of the Code; to the extent that such amount is recognized under section 951(a)(1)(A) or (B) of the Code.

Subpart F Income shall have the meaning as defined in Section 3.5.

Subpart F Income has the meaning ascribed to such term in Section 952 of the Code.

Examples of Subpart F Income in a sentence

• Repeal of Treatment of Foreign Base Com- pany Oil Related Income as Subpart F Income (sec.

• TheC.F.C. rules are designed to discourage the retention of earnings at the level of theC.F.C. Instead of deferral of tax, the C.F.C. rules force a U.S. shareholder owning 10% or more of the voting stock to include in a U.S. tax return the earnings generated from Subpart F Income, typically Foreign Base Company Sales Income and Foreign Personal Holding Company Income.

• Repeal of Inclusion Based on Withdrawal of Previously Excluded Subpart F Income from Qualified Investment (sec.

• Gross Income Taken into Account in Determining Subpart F Income Another item excluded from gross tested income is gross income taken into account in determining a corporation’s subpart F income.

• Residency issues; source of income; tax havens; unilateral relief and Double Tax Avoidance; transfer pricing; international merger and acquisitions; impact of tax on GATT 94, WTO, anti dumping processing; the subpart F Regime : definition of CFC, Subpart F Income and Operating Rules.

More Definitions of Subpart F Income

Subpart F Income. (as defined in Section 952 of the Code) on its United States federal income tax return, or (C) to allow such Shareholder to otherwise comply with applicable United States federal income tax Laws (including with respect to the making of any determinations under Section 951A of the Code); provided that the Company may require such Shareholder to enter into a confidentiality agreement in customary form.

Subpart F Income means any amounts required to be included in gross income of the Company or any if its Subsidiaries pursuant to Section 951 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.

Subpart F Income has the meaning ascribed to it in Clause 6.2(a);

Subpart F Income bears the meaning set out in section 952 of the Code; “Subscription Price” bears the meaning set out in the Articles; “Subsidiary” means any subsidiary of the Company; Execution

Subpart F Income shall have the meaning set forth in Code Section 952. Subpart F income generally includes the receipt by a controlled foreign corporation (a “CFC”) of (a) dividends, interest, rents and royalties, (b) gains from the disposition of assets which generate dividends, interest, rents or royalties, (c) fees for the performance of services performed for related persons outside the CFC’s country of incorporation, (d) profits from the sale of goods purchased or sold from or to a related party for use outside the CFC’s country of incorporation and (e) net foreign currency gain.

Subpart F Income. (as defined in Section 952(a) of the Code), “global intangible low-taxed income” (as defined in Section 951A(b) of the Code) or amount determined under Section 956 of the Code for the portion of the taxable period of the Company or any of the Company Subsidiaries ending on the Closing Date and assuming for this purpose that the taxable period of any “controlled foreign corporation” (as defined under Section 957 of the Code) giving rise to such income or amount ends on the day after the Closing Date; (vi) deferred intercompany gain or any excess loss account described in Treasury Regulations under Section 1502 of the Code (or any corresponding or similar provision of state, local or foreign Tax Applicable Law); or (vii) use of an improper method of accounting for a Tax period ending on or prior to the Closing Date.

Subpart F Income. (as defined in Section 952(a) of the Code) or amounts determined under Section 956 of the Code arising or generated during any Tax period (or portion thereof) ending on or prior to the Closing Date; (ix) inclusion under Section 965(a) of the Code (or any corresponding or similar provision of federal, provincial, territorial, state, municipal, county, local, foreign or other Tax Law) or any election under Section 965(h) of the Code (or any corresponding or similar provision of federal, provincial, territorial, state, municipal, county, local, foreign or other Tax Law); or (x) subsequent inclusion of income related to any reserve, credit or deduction for Tax purposes claimed prior to the Closing Date.