Controlled Foreign Corporation means “controlled foreign corporation” as defined in the Tax Code.
Controlled Foreign Corporation means a “controlled foreign corporation” as defined in Section 957(a) of the Code.
Controlled Foreign Corporation means any Subsidiary which is (i) a “controlled foreign corporation” (within the meaning of Section 957 of the Code), (ii) a subsidiary substantially all the assets of which consist of debt or equity in Subsidiaries described in clause (i) of this definition, or (iii) an entity treated as disregarded for U.S. federal income tax purposes that owns more than 65% of the voting stock of a Subsidiary described in clause (i) or (ii) of this definition.
Examples of Controlled Foreign Corporation in a sentence
Schedule M (Form 5471) (Transactions Between Controlled Foreign Corporation and Shareholders or Other Related Persons ) 12.
Schedule J (Form 5471) (Accumulated Earnings and Profits (E&P) of Controlled Foreign Corporation) 9.
More Definitions of Controlled Foreign Corporation
Controlled Foreign Corporation means any foreign corporation if more than 50 percent of the total combined voting power of all classes of stock of such corporation entitled to vote, or the total value of the stock of such corporation, is owned, or is considered as owned, by “United States shareholders” on any day during the taxable year of such foreign corporation. The term a “United States shareholder” means, with respect to any foreign corporation, a United States person who owns, or is considered as owning, 10 percent or more of the total combined voting power of all classes of stock entitled to vote of such foreign corporation.
Controlled Foreign Corporation means “controlled foreign corporation” as defined in the United States Internal Revenue Code of 1986, as amended from time to time.
Controlled Foreign Corporation means any Subsidiary which is (i) a “controlled foreign corporation” (within the meaning of Section 957 of the Code), (ii) a Subsidiary substantially all the assets of which consist (directly or indirectly through one or more flow-through entities) of Equity Interests and/or indebtedness of one or more Subsidiaries described in clause (i) of this definition, or (iii) an entity treated as disregarded for U.S. federal income tax purposes and substantially all of the assets of which consist (directly or indirectly through one or more flow-through entities) of the Equity Interests and/or indebtedness of one or more Subsidiaries described in clause (i) or (ii) of this definition.
Controlled Foreign Corporation means “controlled foreign corporation” as defined in the IRC.
Controlled Foreign Corporation means “controlled foreign corporation” as defined in the Code.
Controlled Foreign Corporation means any entity which (a) is a “controlled foreign corporation” (within the meaning of Section 957 of the Code) or (b) substantially all the assets of which consist of equity or debt in entities described in clause (a) of this definition.
Controlled Foreign Corporation has the meaning given to such term in Section 957 of the Code.