Overall Foreign Loss Clause Samples
The Overall Foreign Loss clause defines how losses incurred by a taxpayer from foreign sources are treated for tax purposes. Typically, this clause outlines the method for calculating, reporting, and potentially offsetting foreign losses against foreign income, often requiring separate tracking of such losses to prevent them from reducing domestic taxable income. Its core function is to ensure that foreign losses are properly accounted for and do not inappropriately reduce a taxpayer’s domestic tax liability, thereby maintaining the integrity of the tax system and preventing double-dipping of loss deductions.
Overall Foreign Loss. Immediately before the Exchange, the Clorox Affiliated Group does not have an overall foreign loss within the meaning of Section 904(f)(2) and Treas. Reg. § 1.1502-9.
Overall Foreign Loss. Neither the Company nor any of its Subsidiaries has been at any time subject to the overall foreign loss provisions of Section 904(f) of the Code.
Overall Foreign Loss. There is no overall foreign loss of the Company or any of its Subsidiaries under Treasury Regulation Section 1.1502-9 which is subject to recapture.
Overall Foreign Loss. No Acquired Company has sustained an “overall foreign loss” (as defined in Section 904(f) of the Code) for any taxable year.