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

• 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.

• In the event that the Company or any of its subsidiaries is determined by counsel or accountants for any Warrantholder 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 Investor to otherwise comply with applicable United States federal income tax laws; provided that the Company may require such Investor 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(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.