Foreign Corporation Status definition
Foreign Corporation Status means the status of Adient as a foreign corporation (within the meaning of Sections 7701(a)(3) and 7701(a)(5) of the Code) for U.S. federal tax purposes as of immediately after the Distribution.
Foreign Corporation Status means the status of Adient as a foreign corporation (within the meaning of Sections 7701(a)(3) and 7701(a)(5) of the Code) for U.S. federal tax pur- poses as of immediately after the Distribution. “Foreign Income Tax” means any Tax imposed by any foreign country or any possession of the United States, or by any political subdivision of any foreign country or United States possession, which is an income tax as defined in Treasury Regulations Section 1.901-2. “Foreign Other Tax” means any Tax imposed by any foreign country or any pos- session of the United States, or by any political subdivision of any foreign country or United States possession, other than any Foreign Income Taxes. “Former Adient Group Employees” has the meaning provided in the Employee Matters Agreement. “Former ▇▇▇▇▇▇▇ Controls Group Employee” has the meaning provided in the Employee Matters Agreement. “Group” means the ▇▇▇▇▇▇▇ Controls Group or the Adient Group, or both, as the context requires. “High-Level Dispute” means any dispute or disagreement (a) relating to liability under Section 6.04 or (b) in which the amount of liability in dispute exceeds $10 million. “Income Tax” means any Federal Income Tax, State Income Tax or Foreign In- come Tax. “Indemnitee” has the meaning set forth in Section 12.03. “Indemnitor” has the meaning set forth in Section 12.03. “IRS” means the United States Internal Revenue Service. “Jersey SpinCo” means Adient Global Holdings Ltd, a Jersey public limited com- pany and a direct wholly owned Subsidiary of Adient immediately following the Distribution. “Jersey SpinCo Shares” means the ordinary shares, par value £1 per share, of Jer- sey SpinCo. “▇▇▇▇▇▇▇ Controls” has the meaning set forth in the Preamble. “▇▇▇▇▇▇▇ Controls Business” has the meaning set forth in the Separation and Dis- tribution Agreement.
Examples of Foreign Corporation Status in a sentence
For more information, please refer to Section XIII.E.5, Controlled Foreign Corporation Status.