U.S. Matters. (a) Each of Red Gaming Limited and Cyberview Czech is treated as a controlled foreign corporation as defined under section 957 of the Code and the regulations thereunder. Other than the Company and Barcrest Group Technology Limited, no Group Company has an election in effect for purposes of section 7701 of the Code, and the regulations thereunder, to be treated as something other than a corporation for US federal income tax purposes. (b) No Group Company has an account for the purposes of section 952(c) of the Code, and the regulations thereunder.
Appears in 2 contracts
Sources: Share Purchase Agreement, Share Purchase Agreement (Scientific Games Corp)