Code Section 951 definition

Code Section 951 means 26 U.S.C. § 951 or any similar statute hereafter enacted having substantially the same purpose and effect as such Code Section.
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Code Section 951 means 26 U.S.C. § 951 or any similar statute hereafter enacted having substantially the same purpose and effect as such Code Section. "Code Section 951(a)" shall mean 26 U.S.C. § 951(a) or any similar statute hereafter enacted having substantially the same purpose and effect as such Code Section. "Code Section 951(b)" shall mean 26 U.S.C. § 951(b) or any similar statute hereafter enacted having substantially the same purpose and effect as such Code Section.
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Code Section 951 means 26 U.S.C. § 951 or any similar statute hereafter enacted having substantially the same purpose and effect as such Code Section. “Code Section 951(a)” shall mean 26 U.S.C. § 951(a) or any similar statute hereafter enacted having substantially the same purpose and effect as such Code Section. “Code Section 951(b)” shall mean 26 U.S.C. § 951(b) or any similar statute hereafter enacted having substantially the same purpose and effect as such Code Section. “Code Section 957” shall mean 26 U.S.C. § 957 or any similar statute hereafter enacted having substantially the same purpose and effect as such Code Section. “Code Section 1291” shall mean 26 U.S.C. § 1291 or any similar statute hereafter enacted having substantially the same purpose and effect as such Code Section. “Code Section 1295” shall mean 26 U.S.C. § 1295 or any similar statute hereafter enacted having substantially the same purpose and effect as such Code Section. “Code Section 1297” shall mean 26 U.S.C. § 1297 or any similar statute hereafter enacted having substantially the same purpose and effect as such Code Section. Appendix A to Amended and Restated Shareholders’ Agreement
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Examples of Code Section 951 in a sentence

  • The Company further agrees to provide to the Accounting Firm and SOF all information and reasonable access to its books and records necessary or helpful to the Accounting Firm, as requested by such Accounting Firm or SOF, to carry out the Accounting Firm’s duties under this Section and otherwise for SOF to determine and comply with its reporting and tax payment obligations under Code Section 951.

  • The Company further agrees to provide to the Accounting Firm and SOF all information and reasonable access to its books and records necessary or helpful to the Accounting Firm, as requested by such Accounting Firm or SOF, to carry out the Accounting Firm's duties under this Section and otherwise for SOF to determine and comply with its reporting and tax payment obligations under Code Section 951.

  • For purposes of Section 7.3(c), the Taxes payable by the Company or any of its Subsidiaries pursuant to Code Section 951 and attributable to the Pre-Closing Tax Period will deemed to be the amount that would have been payable if the taxable year of the applicable “controlled foreign corporation” had ended as of the close of the Closing Date.

  • None of the Company and its Subsidiaries is a United States Shareholder (as defined in Code Section 951) of any controlled foreign corporation.

  • Notwithstanding the foregoing, all Taxes attributable to income includable under Code Section 951 with respect to the operations and activities of the Company’s foreign Subsidiaries for the Pre-Closing Tax Period included in the last Straddle Period beginning prior to the Closing Date shall be included in the portion of the Straddle Period ending on the Closing Date, even if such income is includable after the Closing Date.

  • The Company shall use its reasonable best efforts to cause its Subsidiaries to avoid recognizing income that would be includible by the Company and its Members under Code Section 951; PROVIDED THAT the Company and its Subsidiaries shall be free to take actions which will result in income includible by the Company and its Members so long as the Company pays tax distributions to the Members with respect to such income under Section 3.1(b).

  • The Company further agrees to provide to the Accounting Firm and SOF all information and reasonable access to its books and records necessary or helpful to the Execution Version Accounting Firm, as requested by such Accounting Firm or SOF, to carry out the Accounting Firm’s duties under this Section and otherwise for SOF to determine and comply with its reporting and tax payment obligations under Code Section 951.

  • For the further avoidance of doubt, any US federal taxable income realized by the Company and its Subsidiaries under Code Section 951 that results from, or to the extent is increased by, any action taken by the Buyer, the Company, or their respective Affiliates after the Closing shall be considered to occur in a taxable period that begins after the Closing Date for purposes of this Section 10.01(a) and Article VIII.