U.S.-Owned DRE definition
U.S.-Owned DRE means any entity that (A) is disregarded as an entity separate from its owner for U.S. federal tax purposes and is directly owned by the U.S. Borrower or a U.S. Subsidiary or (B) is treated as a partnership for U.S. federal tax purposes and all of the partners of which are domestic corporations for U.S. federal tax purposes, and, in the case of clause (A) or (B), that directly owns Equity Interests in a Foreign Subsidiary and does not own any significant asset other than Equity Interests and Securities of Foreign Subsidiaries.
U.S.-Owned DRE means any Person that (i) is not treated as a corporation for US federal income tax purposes, (ii) is 100% owned (directly or indirectly) by Parent or any US Subsidiary and (iii) substantially all the assets of which consist of the stock of one or more controlled foreign corporations within the meaning of Section 957 of the Code.
U.S.-Owned DRE means any entity that (i) is directly owned by Holdings, U.S. Holdings, the Borrower or any Domestic Subsidiary of Holdings, U.S. Holdings or the Borrower and (ii) has no material assets other than Capital Stock of one or more CFCs.
More Definitions of U.S.-Owned DRE
U.S.-Owned DRE means any Person that (i) is not treated as a corporation for US federal income tax purposes, (ii) is 100% owned (directly or indirectly) by the Borrower or any US Subsidiary and (iii) substantially all the assets of which consist of the stock of one or more controlled foreign corporations within the meaning of Section 957 of the Code.
U.S.-Owned DRE means any entity that (i) is not treated as a corporation for U.S. federal income tax purposes; (ii) is directly owned by Holdings, the U.S. Borrower or any Domestic Subsidiary of Holdings or the U.S. Borrower and (iii) all of the material assets of which are Capital Stock of one or more controlled foreign corporations within the meaning of Section 957 of the Code.
U.S.-Owned DRE means any entity that (i) is a Domestic Subsidiary; (ii) is not treated as a corporation for U.S. federal income tax purposes; (iii) is directly owned by the Borrower or any Guarantor; and (iv) owns in excess of 65% of the total voting power of all outstanding voting stock or interests in a Foreign Subsidiary.
U.S.-Owned DRE any entity (i) that is a Subsidiary of the Borrower or any Domestic Subsidiary of the Borrower and (ii) substantially all of the material assets of which are Capital Stock of one or more controlled foreign corporations within the meaning of Section 957 of the Code.