Flow-Thru Entity definition

Flow-Thru Entity means (i) any entity, plan or arrangement that is treated for income Tax purposes as a partnership, (ii) a “controlled foreign corporation” within the meaning of Code Section 957, or (iii) a “passive foreign investment corporation” within the meaning of Code Section 1297.
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Flow-Thru Entity means any entity, plan or arrangement that is treated for income Tax purposes as a partnership.
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Flow-Thru Entity means (a) any entity, plan or arrangement that is treated for U.S. federal income Tax purposes as a partnership, (b) a “specified foreign corporation” within the meaning of Code Section 965 or (c) a “passive foreign investment corporation” within the meaning of Code Section 1297.
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Examples of Flow-Thru Entity in a sentence

  • The Company does not own an interest in any Flow-Thru Entity and neither the Company nor any of its Affiliates is a party to any joint venture, partnership or other arrangement or contract that would be treated as a partnership for U.S. federal income Tax purposes.

  • None of the Transferred Companies or their Subsidiaries own an interest in any Flow-Thru Entity.

  • Notwithstanding anything herein to the contrary, the Company Unitholders at their sole cost and expense, shall be solely responsible for filing all of the Tax Returns required to be filed by the Company Unitholders and paying all of the Taxes due and owing by the Company Unitholders (including to the extent attributable to income of any Group Company that flows up to Company Unitholders) in respect of their direct or indirect ownership of any member of the Company Group that is a Flow-Thru Entity.

  • TABLE OF CONTENTS​ (q) No Company Party owns an interest in any Flow-Thru Entity.

  • PTIC II does not own and has not owned in the last three (3) years an interest in any Flow-Thru Entity.


More Definitions of Flow-Thru Entity

Flow-Thru Entity means: (a) any entity, plan or arrangement that is treated for Income Tax purposes as a partnership; (b) a “controlled foreign corporation” within the meaning of Section 957 of the Code; or (c) a “passive foreign investment corporation” within the meaning of Section 1297 of the Code.
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Flow-Thru Entity means (a) (i) any entity, plan or arrangement that is treated for income Tax purposes as a disregarded entity or partnership, (ii) a “specified foreign corporation” within the meaning of Code Section 965 or (iii) a “passive foreign investment corporation” within the meaning of Code Section 1297, or (b) any entity with respect to which a holder of a (direct or indirect) equity interest in the entity is (or could be) subject to Tax under the Code (or other applicable Laws relating to Taxes) by reference to earnings, income, assets, or activities of the entity.
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Flow-Thru Entity means any entity, plan or arrangement that is treated for federal income Tax purposes as a partnership.
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Flow-Thru Entity has the meaning set forth in Section 6.02(a).
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Flow-Thru Entity means (a) any entity, plan or arrangement that is treated for income Tax purposes as a partnership or a disregarded entity, (b) a “specified foreign corporation” within
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Flow-Thru Entity means (i) (a) any entity, plan or arrangement that is treated for Income Tax purposes as a partnership, (b) a “controlled foreign corporation” within the meaning of Code section 957, or (c) a “passive foreign investment corporation” within the meaning of Code section 1297 or (ii) with respect to which a holder of a (direct or indirect) equity interest in the entity is (or could be) subject to Tax under the Code (or other applicable domestic law relating to Taxes) by reference to earnings, income, assets, or activities of the entity. Notwithstanding the foregoing, no Subsidiary shall constitute a Flow-Thru Entity as a result of the application of consolidated return provisions under Code section 1504 and the Treasury Regulations promulgated thereunder (or any similar provision of state, local, or non-U.S. Applicable Laws).
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Flow-Thru Entity means (a) any entity, plan or arrangement that is treated for income Tax purposes as a partnership, (b) a “controlled foreign corporation” within the meaning of Code
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