Passive Foreign Investment Company definition

Passive Foreign Investment Company. (in each case as defined in the U.S. Internal Revenue Code and the regulations issued thereunder) or otherwise.
Passive Foreign Investment Company shall have the meaning as set out in Code Section 1297.
Passive Foreign Investment Company. The Company is not, and will not be, either after receipt of payment for the Shares or after the application of the proceeds therefrom as described under “Use of Proceeds” in the Registration Statement or the Prospectus, required to register as an “investment company” under the Investment Company Act of 1940, as amended (the “Investment Company Act”). Based on certain estimates, including as to the relative values of its assets, the Company believes that it was likely not a PFIC for its 2019 taxable year.

Examples of Passive Foreign Investment Company in a sentence

  • One example of this is the Passive Foreign Investment Company (PFIC) regulations.

  • Restriction on Insurance Business Exception to the Passive Foreign Investment Company Rules (sec.

  • The Company is not a Passive Foreign Investment Company (“PFIC”) within the meaning of Section 1296 of the United States Internal Revenue Code of 1966, and the Company is not likely to become a PFIC.

  • The Company is not a Passive Foreign Investment Company (“ PFIC”) within the meaning of Section 1296 of the Code, and the Company is not likely to become a PFIC.

  • The organizational documents of NewCo shall contain customary provisions relating to the prompt determination and provision of information relating to, among other things the U.S. federal income tax rules applicable Passive Foreign Investment Company (“PFIC”), including with respect to elections that are relevant to the treatment of PFIC stock, if applicable, and Controlled Foreign Corporations (“CFCs”).


More Definitions of Passive Foreign Investment Company

Passive Foreign Investment Company shall have the meaning as set out in Code Section 1297. Appendix A to Amended and Restated Shareholders’ Agreement
Passive Foreign Investment Company. The Company is not, and will not, be, either after receipt of payment for the Offered ADSs or after the application of the proceeds therefrom as described under the “Use of Proceeds” in the Registration Statement, the Time of Sale Prospectus or the Prospectus, required to register as an “investment company” under the Investment Company Act of 1940, as amended (the “Investment Company Act”). Based on the analysis of the Company’s activities and current estimates of the composition of its income and assets (including goodwill), the Company does not expect to be a passive foreign investment company (a “PFIC”), as defined in Section 1297 of the Code, for the current taxable year or in the foreseeable future. Neither the Company nor any Subsidiary is, and, after giving effect to the offering and sale of the Offered ADSs and the application of the proceeds thereof, neither of them will be, a “controlled foreign corporation” as defined by the Code.
Passive Foreign Investment Company or “PFIC” shall have the meaning as set forth in the Internal Revenue Code.
Passive Foreign Investment Company. (in each case as defined in the U.S. Internal Revenue Code and the regulations issued thereunder) or otherwise. The Depositary agrees to use reasonable efforts to follow the procedures established by the French Treasury to enable U.S. resident Beneficial Owners eligible to recover any excess French withholding taxes initially withheld or deducted with respect to dividends and other distributions of the Company to such Beneficial Owners, and to receive any payment in respect of the "avoir fiscal" for which such Beneficial Owners may be eligible from French Treasury.
Passive Foreign Investment Company. The Company is not, and will not be, either after receipt of payment for the Offered Shares or after the application of the proceeds therefrom as described under “Use of Proceeds” in the Registration Statement, the Time of Sale Prospectus or the Prospectus, required to register as an “investment company” under the Investment Company Act of 1940, as amended (the “Investment Company Act”). Based on certain estimates, including as to the relative values of its assets, the Company believes that it was likely a passive foreign investment company, within the meaning of Section 1297 of the Internal Revenue Code of 1986, as amended, for its 2016 taxable year.
Passive Foreign Investment Company. The Company is not, and will not be, either after receipt of payment for the Offered Shares or after the application of the proceeds therefrom as described under “Use of Proceeds” in the Registration Statement, the Time of Sale Prospectus or the Prospectus, required to register as an “investment company” under the Investment Company Act of 1940, as amended (the “Investment Company Act”). As of March 31, 2016, the Company would not have been considered a “passive foreign investment company,” as such term is defined in the Code, and immediately after the offering and sale of the Offered Shares and assuming the application of the proceeds as described in the Time of Sale Prospectus under “Use of Proceeds,” less than 50% of the Company’s assets will be classified as assets that produce, or are held for the production of, passive income for the purpose of Section 1297 of the Code and the rules, regulations and administrative pronouncements relating thereto. Neither the Company nor any Subsidiary is, and, after giving effect to the offering and sale of the Offered Shares and the application of the proceeds thereof, neither of them will be, a “controlled foreign corporation” as defined by the Code.
Passive Foreign Investment Company. The Company is not, and will not be, either after receipt of payment for the Offered ADSs or after the application of the proceeds therefrom as described under “Use of Proceeds” in the Registration Statement, the Time of Sale Prospectus or the Prospectus, required to register as an “investment company” under the Investment Company Act of 1940, as amended (the “Investment Company Act”). As of December 31, 2016, the Company believes that it is more likely than not that it would not have been considered a “passive foreign investment company,” as such term is defined in the Code. To the Company’s knowledge, neither the Company nor any subsidiary of the Company is, and, after giving effect to the offering and sale of the Offered ADSs and the application of the proceeds thereof, neither of them is expected to be, a “controlled foreign corporation” as defined by the Code.