Examples of Blocker Corporations in a sentence
Brunson, Repatriating Tax-Exempt Investments: Tax Havens, Blocker Corporations, and Unrelated Debt-Financed Income, 106 NW.
The parties hereto further acknowledge that the Blocker Corporations may have certain tax attributes at the time of such Blocker Merger to which Parent could inherit in the Blocker Merger under the Code or similar provisions of U.S. federal, state or local and foreign tax law arising from basis adjustments pursuant to Section 743 of the Code and the regulations thereunder.
This option is discussed in Norman Silber and John Wei, The Use of Foreign Blocker Corporations by U.S. Nonprofits: Should Blockers be Blocked?, Hofstra Law, Legal Studies Research Paper No. 2016-04, October 28, 2016, available at https://ssrn.com/abstract=2860107.
Blocker Corporations to Avoid UBITA method by which tax-exempt organizations can legally avoid paying UBIT on hedge fund investments is through the use of a blocker corporation.
SkyTerra shall have entered into binding agreements to acquire (x) all of the equity of MSV Investors, LLC not currently owned, directly or indirectly, by SkyTerra and (y) 100% of the MSV LP Units and MSV GP Shares held by the Columbia/Spectrum Blocker Corporations, in each case, such acquisition to occur no later than one day after the Initial Closing Date.
Each Member shall be permitted to implement any internal restructuring of any affiliated Blocker Corporations and special purpose vehicles so that any Blocker Corporation becomes a direct owner of Units and to facilitate the sale described in this Section 14.2.
Brunson, Repatriating Tax-Exempt Investments: Tax Havens, Blocker Corporations, and Unrelated Debt-Financed Income, 106 Nw. U.
If an Exchange or Reorganization Transaction subsequently occurs with respect to Units (including Units held by Blocker Corporations) for which the Corporation has exercised its termination rights under this Section 4.1(a) and paid all amounts owed in connection with the exercise of such rights, the Corporation shall have no obligations under this Agreement with respect to such Exchange or Reorganization Transaction.
The General Partner will cause each ECI Blocker Partner, FIRPTA Blocker Partner and UBTI Blocker Partner to participate in each applicable Portfolio Company through one or more Blocker Corporations.
SkyTerra shall have taken all actions necessary to consummate the Closing under each of the exchange agreements between SkyTerra and each of Other Blocker Corporations.