Foreign Source Income Sample Clauses

Foreign Source Income. Each of Synergy and each Seller is classified as a foreign corporation for U.S. tax purposes or would be so classified if such classification were relevant for any purpose. More than 80% of the gross income of each of Synergy and each Seller for the past three years has been derived from sources without the United States.

Foreign Source Income. Amounts paid as compensation for services do not fail to be treated as §415 compensation merely because those amounts are not includible in gross income on account of the location of the services or merely because those amounts are paid by an employer with respect to which all compensation paid by such employer is excluded from gross income. Thus, for example, the determination of whether an amount is §415 compensation shall be made without regard to the exclusions from gross income under sections 872, 893, 894, 911, 931 and 933 of the Code.

Foreign Source Income. For the avoidance of doubt, to the extent that ▇▇▇▇ ▇▇▇ derives any additional Tax Benefit (other than the FSC Benefit and the FTC Benefit) as a result of foreign source income generated by Coach's export sales during any Interim Period, ▇▇▇▇ ▇▇▇ shall be solely entitled to, and shall not compensate Coach for, such additional Tax Benefit.