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 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.

• Under the Subpart F rules, the earnings of a C.F.C. that are categorized as Subpart F Income may be taxed when and as earned at the level of its U.S. Shareholders even if no dividend is distributed.A foreign corporation is a C.F.C. if shares representing more than 50% of its voting power or value are owned by U.S. Shareholders.

• 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.

• Total Net Income in Subpart F Income Group(in functional currency of foreign corporation)7.

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 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 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 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(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.