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.

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

Subpart F Income bears the meaning set out in section 952 of the Code;

Examples of Subpart F Income in a sentence

For the avoidance of doubt, this shall include any liability for Taxes imposed with respect to Subpart F Income accrued by a CFC that is a member of the SpinCo Group even if the Subpart F Income accrued in a Straddle Period for that CFC.
In addition, the Company shall provide the Investors with access to such other Company information as may be necessary for the Investors to determine the Company’s status as a CFC and to determine whether Series A Investor or any of the Investor’s Partners is required to report its pro rata portion of the Company’s Subpart F Income on its United States federal income tax return, or to allow such Investor or such Investor’s Partners to otherwise comply with applicable United States federal income tax laws.
In addition, the Company shall provide the Purchasers with access to such other Company information as may be necessary for the Purchasers to determine the Company’s status as a CFC and to determine whether Purchaser or any of Purchaser’s Partners is required to report its pro rata portion of the Company’s Subpart F Income on its United States federal income tax return, or to allow such Purchaser or such Purchaser’s Partners to otherwise comply with applicable United States federal income tax laws.
In the event that the Company or any of its subsidiaries is determined by counsel or accountants for any Noteholder to be a CFC as defined in the Code, the Company agrees to use commercially reasonable efforts, to the extent not inconsistent or incompatible with the Company’s, or if applicable, any subsidiary’s, current or intended business operations, plans or objectives, to avoid generating Subpart F Income (as defined below).
If the Company is, in the reasonable opinion of its US tax advisors or a US Tax Investor, a CFC, the Company shall use commercially reasonable efforts to avoid generating Subpart F Income.

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

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 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;

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 means “subpart F income” as defined in Section 952 of the Code and the Treasury Regulations thereunder, and “Section 956 Amount” means any amount described in Sections 951(a)(1)(B) and 956 of the Code and the Treasury Regulations thereunder. Without limiting the Company’s obligations as set forth in this Section 1.9, for the avoidance of doubt, neither the Company nor other shareholders (including the Key Holders) are responsible for any tax filings of the United States based Investors or for any associated or related costs incurred in connection with such tax filings.

Subpart F Income. (as defined in Section 952 of the Code) or its “global intangible low-taxed income” (“GILTI”) (as defined in Section 951A of the Code) on its United States federal income tax return, or to allow such Investor (and any person who is a direct or indirect interest holder in such Investor) to otherwise comply with all provisions of the Code and U.S. Treasury Regulations with respect to CFCs. The Company shall make reasonable inquiry with its tax advisors on at least an annual basis, and in any event no later than two (2) months following the end of each Taxable Year, regarding its (and its subsidiaries’) status as a CFC, and if the Company is informed by its tax advisors that it (or any subsidiary) has become a CFC, or that there is a likelihood of the Company (or any subsidiary) being classified as a CFC for any Taxable Year, the Company shall promptly notify the Investors of such status or risk, as the case may be. In the event that Company (or any subsidiary) is determined by the Company’s tax advisors or by counsel or accountants for an Investor to be a CFC, the Company agrees to make due inquiry with its tax advisors regarding whether any portion of the Company’s (or a subsidiary’s) income is Subpart F income or GILTI.