Foreign DRE definition

Foreign DRE means a Foreign Subsidiary that for U.S. Federal income tax purposes is classified as a partnership or that is “disregarded as an entity separate from its owner” (within the meaning of Treas. Reg. §301.7701-2), but not any such Foreign Subsidiary whose assets consist solely of stock of a “controlled foreign corporation” (within the meaning of Section 957(a) of the Code).
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Foreign DRE a Foreign Subsidiary that for U.S. federal income tax purposes is classified as a partnership or that is “disregarded as an entity separate from its owner” (within the meaning of Treas. Reg. § 301.7701-3), but not any such Foreign Subsidiary that has no material assets other than Capital Stock of one or more Foreign Subsidiaries that are CFCs.
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Foreign DRE means a Domestic Subsidiary meeting the criteria set forth in clause (b) of the definition of the term "Domestic Subsidiary" but not meeting the criteria set forth in clause (a) of the definition of such term.
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Examples of Foreign DRE in a sentence

  • Distributing will transfer the Controlled stock for no consideration to Foreign DRE (the Distribution).In connection with the Contribution and Distribution, Distributing and Controlled will have certain continuing relationships that will be formalized in agreements between them (Continuing Relationships).

  • Foreign Sub, a wholly owned Country F company of Foreign Parent, will elect to be classified as an entity disregarded from Foreign Parent (hereinafter Foreign DRE).


More Definitions of Foreign DRE

Foreign DRE means a Foreign Subsidiary that for U.S. Federal income tax purposes is classified as a partnership or that is “disregarded as an entity separate from its owner” (within the meaning of Treas. Reg. §301.7701-2), but not any such Foreign Subsidiary whose assets consist solely of stock of a “controlled foreign corporation” (within the meaning of Section 957(a) of the Code). “Foreign Lender” means any Lender that is organized under the laws of a jurisdiction other than the United States, each State thereof or the District of Columbia. “Foreign Subsidiary” means each Subsidiary of the Company that is not a Domestic Subsidiary. “Fronting Exposure” means, at any time there is a Defaulting Lender, (a) with respect to any Issuing Bank, such Defaulting Lender’s Applicable Percentage of the outstanding LC Exposure with respect to Letters of Credit issued by such Issuing Bank other than LC Exposure as to which such Defaulting Lender’s participation obligation has been reallocated to other Lenders or Cash Collateralized in accordance with the terms hereof, and (b) with respect to any Swingline Lender, such Defaulting Lender’s Applicable Percentage of Swingline Exposure other than Swingline Exposure as to which such Defaulting Lender’s participation obligation has been reallocated to other Lenders. “FSA” means the Food Security Act of 1985, 7 U.S.C. Section 1631 et seq . “Fully Satisfied” or “Full Satisfaction” means, as of any date, that on or before such date: (a) with respect to the Loans and Letters of Credit: (i) the principal of and interest accrued to such date on the Loans (other than the contingent LC Exposure) shall have been paid in full in cash, (ii) all fees, expenses, and other amounts then due and payable (other than the contingent LC Exposure and other contingent amounts for which a claim has not been made) shall have been paid in full in cash, (iii) the Commitments shall have expired or irrevocably been terminated, and (iv) the contingent LC Exposure, if any, shall have been secured by: (A) the grant of a first-priority, perfected Lien on cash in an amount at least equal to 105% of the amount of such LC Exposure or other collateral which 25
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Foreign DRE means a Foreign Subsidiary that for U.S. Federal income tax purposes is classified as a partnership or that is “disregarded as an entity separate from its owner” (within the meaning of Treas. Reg. §301.7701-2), but not any such Foreign Subsidiary whose assets consist solely of stock of a “controlled foreign corporation” (within the meaning of Section 957(a) of the Code). “Foreign Lender” means any Lender that is organized under the laws of a jurisdiction other than the United States, each State thereof or the District of Columbia. “Foreign Subsidiary” means each Subsidiary of the Company that is not a Domestic Subsidiary.
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Related to Foreign DRE

  • foreign vessel means any vessel other than a coastal vessel.

  • Foreign Investment means any investment made by a person resident outside India on a repatriable basis in capital instruments of an Indian company or to the capital of an LLP;

  • foreign firm means a business entity owned or controlled by one or more foreign nationals or a business entity in which more than 50 percent of the stock is owned or controlled by one or more foreign nationals.

  • foreign ship means a ship which—

  • foreign investor means a natural person of a third country or an undertaking of a third country, intending to make or having made a foreign direct investment;

  • foreign national means the following:

  • Foreign Air Carrier means any air carrier which is not a U.S. Air Carrier and which performs maintenance, preventative maintenance and inspections for the Aircraft, Airframe and/or any Engine or engine to standards which are approved by, or which are substantially equivalent to those required by, the Federal Aviation Administration, the Civil Aviation Authority of the United Kingdom, the Direction Generale de l'Aviation Civile of the French Republic, the Luftfahrt Bundesamt of the Federal Republic of Germany, the Rijflauchtraatdienst of the Kingdom of the Netherlands, the Ministry of Transportation of Japan or the Federal Ministry of Transport of Canada (and any agency or instrumentality of the applicable government succeeding to the functions of any of the foregoing entities).

  • Foreign government means any jurisdiction other than the one embraced within the United States, its territories, and its possessions.

  • Foreign flag vessel means any vessel that is not a U.S.-flag vessel.

  • Foreign vehicle means every motor vehicle, trailer, or semitrailer that is brought into the

  • Foreign terrorist organization means an organization designated as a foreign terrorist organization by the United States secretary of state as authorized by 8 U.S.C. Section 1189.

  • Foreign with respect to an entity, means an entity governed as to its internal affairs by the law of a jurisdiction other than this state.

  • Foreign market vehicle means any motor vehicle originally manufactured outside the United States,

  • Foreign-going vessel means any vessel other than a coastal vessel.

  • Foreign Asset Sale shall have the meaning provided in Section 5.2(i).

  • Foreign country means a country, including a political subdivision thereof, other than the United States, that authorizes the issuance of support orders and:

  • Foreign tribunal means a court, administrative agency, or quasi-judicial entity of a foreign country which is authorized to establish, enforce, or modify support orders or to determine parentage of a child. The term includes a competent authority under the Convention.

  • 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 Regulation Section 1.901-2, and any interest, penalties, additions to tax, or additional amounts in respect of the foregoing.

  • foreign financial institution means an institution registered as a foreign financial institution with the Ministry of Finance in the Mexican Banking and Financial Institutions, Pensions, Retirement and Foreign Investment Funds Registry for purposes of Article 195, Section I of the Mexican Income Tax Law.

  • Foreign Issuer means “foreign issuer” as that term is defined in Rule 902(e) of Regulation S;

  • United States Tax Person A citizen or resident of the United States, a corporation, partnership or other entity created or organized in, or under the laws of, the United States, any State thereof or the District of Columbia, an estate whose income from sources without the United States is includible in gross income for United States federal income tax purposes regardless of its source or a trust if a court within the United States is able to exercise primary supervision over the administration of the trust and one or more United States Tax Persons have the authority to control all substantial decisions of the trust, all within the meaning of Section 7701(a)(30) of the Code (or, to the extent provided in the applicable Treasury Regulations, certain trusts in existence on August 20, 1996 that have elected to be treated as United States Tax Persons).

  • foreign State means a jurisdiction other than the United States, a state, or a federally recognized Indian tribe.

  • Foreign Assets means any of the Portfolios’ investments (including foreign currencies) for which the primary market is outside the United States and such cash and cash equivalents as are reasonably necessary to effect the Portfolios’ transactions in such investments.

  • Foreigner means a person who is not a citizen of the Republic of South Africa as defined in the South African Citizenship Act, Act Number 88 of 1995, as amended, which Act is available on the Website;

  • foreign fishing vessel means any fishing vessel other than a local fishing vessel;