Disregarded Entity definition
Disregarded Entity means a single member limited liability company, a qualifying subchapter S subsidiary, or another entity if the company, subsidiary, or entity is a disregarded entity for federal income tax purposes.
Disregarded Entity means an entity that, pursuant to Treas. Reg. § 301.7701-2(c)(2), is disregarded for U.S. federal income Tax purposes as an entity separate from its owner.
Disregarded Entity means any entity treated as disregarded as an entity separate from its owner under Treasury Regulations Section 301.7701-3.
Examples of Disregarded Entity in a sentence
Cause (i) one hundred percent (100%) of the issued and outstanding Equity Interests of each Domestic Subsidiary (other than any CFC Holdco or any Excluded Disregarded Entity) directly owned by any Loan Party and (ii) sixty five percent (65%) of the issued and outstanding Equity Interests entitled to vote (within the meaning of Treas.
More Definitions of Disregarded Entity
Disregarded Entity means, with respect to any Person, (i) any “qualified REIT subsidiary” (within the meaning of Code Section 856(i)(2)) of such Person, (ii) any entity treated as a disregarded entity for Federal income tax purposes with respect to such Person, or (iii) any grantor trust if the sole owner of the assets of such trust for Federal income tax purposes is such Person.
Disregarded Entity means a business entity:
Disregarded Entity means any Domestic Subsidiary that is disregarded for U.S. federal income tax purposes.
Disregarded Entity means, with respect to any Person, (i) any “qualified REIT subsidiary” (within the meaning of Code Section 856(i)(2)) of such Person, (ii) any entity treated as a disregarded entity for federal income tax purposes with respect to such Person, or (iii) any grantor trust if the sole owner of the assets of such trust for federal income tax purposes is such Person.
Disregarded Entity. An entity that is both (a) solely owned by a REIT or Qualified REIT Subsidiary and (b) disregarded as an entity separate from its owner within the meaning of Section 301.7701-2(c)(2) of the Treasury Regulations.
Disregarded Entity means a Subsidiary that is a flow-through entity (i.e., a partnership or a disregarded entity) for United States federal income tax purposes and has no material assets other than Equity Interests of one or more Subsidiaries that are “controlled foreign corporations” within the meaning of Section 957(a) of the Internal Revenue Code (each such controlled foreign corporation, a “CFC”).
Disregarded Entity has the meaning set forth in Section 6.17(h).