Excluded Tax Subsidiary means any Restricted Subsidiary that is (i) an Excluded Domestic Subsidiary or (ii) a Foreign Subsidiary that is a CFC.
Excluded Tax Subsidiary means (i) a CFC, (ii) a Foreign Holding Company and (iii) any subsidiary of any CFC.
Excluded Tax Subsidiary means (a) any direct or indirect Foreign Subsidiaries, (b) any direct or indirect Domestic Subsidiary of a controlled foreign corporation within the meaning of Section 957 of the Code and (c) any Subsidiary that is organized in the United States that holds no material assets other than Equity Interests of one or more controlled foreign corporations within the meaning of Section 957 of the Code.
More Definitions of Excluded Tax Subsidiary
Excluded Tax Subsidiary means (a) any Foreign Subsidiary that is not an Included Foreign Subsidiary, (b) any Domestic Subsidiary that has no material assets other than equity and debt interests of one or more direct or indirect Foreign Subsidiaries that are not Included Foreign Subsidiaries and (c) any Domestic Subsidiary that is a subsidiary of a Foreign Subsidiary that is not an Included Foreign Subsidiary; provided, that in no event shall any Excluded Tax Subsidiary (i) own any Material Intellectual Property or any Equity Interests of any Subsidiary of the Borrower that owns any Material Intellectual Property or (ii) be the exclusive licensee of any Material Intellectual Property.
Excluded Tax Subsidiary means (i) a Foreign Subsidiary that is a CFC, (ii) a CFC Holding Company, (iii) a Subsidiary that is owned directly or indirectly by a Foreign Subsidiary that is a CFC and (iv) a Subsidiary with respect to which a guarantee by it of the Loan or any other Obligations would result in adverse tax consequences (including, without limitation, as a result of the operation of Section 956 of the Code or any similar law or regulation in any applicable jurisdiction) as determined in good faith by Debtor and the Administrative Agent. For the avoidance of doubt, and notwithstanding anything to the contrary in this Note, no Excluded Tax Subsidiary shall be required to guaranty any Obligations.
Excluded Tax Subsidiary. (i) any Foreign Holding Company, (ii) any Foreign Subsidiary, and (iii) any Subsidiary of any Person described in the preceding clause (i) or (ii).
Excluded Tax Subsidiary means (a) Foreign Subsidiaries (as defined below) and (b) any subsidiary that is organized in the United States that holds no material assets other than equity interests of one or more Foreign Subsidiaries.
Excluded Tax Subsidiary means (a) any direct or indirect Foreign SubsidiariesSubsidiary, (b) any direct or indirect Domestic Subsidiary of a controlled foreign corporation
Excluded Tax Subsidiary means (a) any Foreign Subsidiary that is not an Included Foreign Subsidiary, (b) any Domestic Subsidiary that has no material assets other than equity and debt interests of one or more direct or indirect Foreign Subsidiaries that are not Included Foreign Subsidiaries, and (c) any Domestic Subsidiary that is a subsidiary of a Foreign Subsidiary that is not an Included Foreign Subsidiary; provided, that in no event shall any Excluded Tax Subsidiary (i) own any Material Intellectual Property or any Equity Interests of any Subsidiary of the Borrower that owns any Material Intellectual Property or (ii) be the exclusive licensee of any Material Intellectual Property.
Excluded Tax Subsidiary means (a) a controlled foreign corporation as defined in Section 957 of the Code the shares of which are treated as owned directly or indirectly by a “United States Shareholder” (within the meaning of Section 951(b) of the Code) as measured for purposes of Section 958(a) of the Code (“CFC”), (b) a direct or indirect subsidiary of a CFC and (c) a subsidiary that owns (directly or indirectly) no material assets other than equity interests (or equity interests and debt interests) of one or more CFCs (a “FSHCO”).