Foreign Losses definition

Foreign Losses means the aggregate balance of all Foreign Subsidiary Obligations, following the acceleration thereof, and after application of all Foreign Subsidiary Collections through the date upon which Agent advises the Lender that in the exercise of Agent's reasonable judgment, no further material Foreign Subsidiary Collection will be realized.
Sample 1Sample 2
Foreign Losses means the aggregate of all monetary losses whatsoever which any BNY Company may suffer or incur by reason of a Foreign Subsidiary's failure to observe or perform in full all of their Foreign Subsidiary Obligations however arising, including but not limited to all liabilities, obligations, losses, damages, penalties, actions, judgments, suits, costs, expenses, fees or disbursements of any kind or nature whatsoever and/or all liabilities of a BNY Company to a Foreign Subsidiary and/or third parties arising out of or related to any Foreign Subsidiary Credit Agreements
Sample 1

Examples of Foreign Losses in a sentence

  • Recapture of Overall Foreign Losses One commentator requested that Treasury and the IRS provide that U.S.- source taxable income arising upon recapture of an overall foreign loss described in section 904(f) be treated as QBI in the recapture year to the extent the overall foreign loss limited the section 199A deduction in a prior tax year.

  • ET Telecoms (2020b) Reliance Jio becomes market leader in Delhi with 1.77 crore subscribers: Trai data - ET Telecom, ETTelecom.com.

  • The Risk Participation shall be payable from time to time by each Lender to Agent on demand following receipt of notice by such Lender of the incurrence by a BNY Company of Foreign Losses and the amount thereof (a "Payment Event").

  • Listed foreign tax attributes included: E&P, Foreign Tax Credit Pools, Net Operating Losses, Overall Foreign Losses, Dual Consolidation Losses, Branch Loss Recapture (Section 367(a)), Cash Needs/Expected Future Dividend Payments, Borrowing Capacity, Section 987 Gain/Loss, Asset/Stock Basis and FMV, Expense Allocation.

  • Payment for completed goods and/or services delivered to and accepted by Align under this Section will be in accordance with the pricing set forth in the relevant P.O. Seller must promptly submit any outstanding invoices for goods and/or services upon termination.

  • Firstly, mixed approach enables researcher to get deeper information by triangulating data gathered through questionnaires and interviews.

  • Cordewener, Foreign Losses, Tax Treaties and EC Fundamental Freedoms: a new German Case before the ECJ, European Taxation (Septem- ber, 2003), 294-303, at 294.

  • See Cordewener/Dahlberg/Pistone/Reimer/Romano, The Tax Treatment of Foreign Losses: Ritter, M & S, and the Way Ahead (Part Two), ET 2004, pp.

  • Article, The Tax Treatment of Foreign Losses: Ritter, M & S, and the Way Ahead(co-authors Cordewener A., Dahlberg M., Reimer E., Romano C.), in European Taxation, 4-5/2004, pp.

  • The amount of U.S. source gain that is recharacterized as foreign source under [I.R.C. §] 904(f)(3) is limited to the amount necessary to recapture of the Overall Foreign Losses (“OFLs”) in the OFL account at the beginning of the year [Y]ourforeign tax credit allowed for [the] tax year ended December 31, 2010 is $0.00 rather than .

Related to Foreign Losses

  • Foreign taxes means value-added taxes and custom duties assessed by a foreign government on a commodity. It does not include foreign sales taxes.

  • Tax Losses has the meaning assigned to such term in Section 7.1(a).

  • foreign tax means any Foreign Income Taxes or Foreign Other Taxes.

  • Indemnified Losses is defined in Section 5.03 of the Servicing Agreement.

  • distribution losses means energy losses that result from the interaction of intrinsic characteristics of the distribution network such as electrical resistance with network voltages and current flows;

  • Fraud Losses Realized Losses on Mortgage Loans as to which a loss is sustained by reason of a default arising from fraud, dishonesty or misrepresentation in connection with the related Mortgage Loan, including a loss by reason of the denial of coverage under any related Primary Insurance Policy because of such fraud, dishonesty or misrepresentation.

  • Non-Income Taxes means any Taxes other than Income Taxes.

  • 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.

  • Tax-Related Losses means (a) all federal, state, local and foreign Taxes (including interest and penalties thereon) imposed (or that would be imposed) pursuant to any settlement, Final Determination, judgment or otherwise; (b) all accounting, legal and other professional fees, and court costs incurred in connection with such Taxes; and (c) all costs, expenses and damages associated with stockholder litigation or controversies and any amount paid by Parent (or any Parent Affiliate) or SpinCo (or any SpinCo Affiliate) in respect of the liability of shareholders, whether paid to shareholders or to the IRS or any other Tax Authority, in each case, resulting from the failure of the Contribution, the First Internal Distribution, the Second Internal Distribution or the Distribution, to have Tax-Free Status.

  • Net After-Tax Benefit means the Present Value of a Payment net of all federal state and local income, employment and excise taxes imposed on Executive with respect thereto, determined by applying the highest marginal rate(s) applicable to an individual for Executive’s taxable year in which the Change in Control occurs.

  • Net Income (Loss) means with respect to any Person and for any period, the aggregate net income (or loss) after taxes of such Person for such period, determined in accordance with GAAP.

  • Buyer Losses has the meaning set forth in Section 10.1(a).

  • Foreign Lender means a Lender that is not a U.S. Person.

  • Tax Benefit means any refund, credit, or other reduction in otherwise required Tax payments.

  • Seller Losses shall have the meaning set forth in Section 9.1(b).

  • Non-Income Tax means any Tax other than an Income Tax.

  • Tax Loss means the taxable income or tax loss of the Trust, determined in accordance with Section 703(a) of the Code, for each Fiscal Year as determined for federal income tax purposes, together with each of the Trust's items of income, gain, loss or deduction which is separately stated or otherwise not included in computing taxable income and tax loss.

  • Connection Income Taxes means Other Connection Taxes that are imposed on or measured by net income (however denominated) or that are franchise Taxes or branch profits Taxes.

  • Carryback means any net operating loss, net capital loss, excess tax credit, or other similar Tax item which may or must be carried from one Tax Period to another Tax Period under the Code or other applicable Tax Law.

  • Tax Detriment means any item of income, gain, recapture of credit or any other Tax Item which increases Taxes paid or payable.

  • Net Tax Benefit has the meaning set forth in Section 3.1(b) of this Agreement.

  • Tax Credits means the low-income housing tax credits found in Section 42 of the Code, and all rules, regulations, rulings, notices and other promulgations thereunder.

  • Non-Income Tax Return means any Tax Return relating to any Tax other than an Income Tax.

  • Transaction Tax Deductions means any Tax deductions relating to (i) the Company Transaction Expenses, and (ii) repayment of the Indebtedness, including any unamortized deferred financing fees in connection with the Indebtedness.

  • Tax Revenue means, with respect to the Project Area, (a) those tax revenues referred to (1) in the last sentence of the first paragraph of Article VIII, Section 12 of the Constitution of the State and (2) in Section 18-2147, Reissue Revised Statutes of Nebraska, as amended, and (b) all payments made in lieu thereof.

  • Direct Losses means all damages, losses, liabilities, penalties, fines, assessments, claims, actions, costs, expenses (including the cost of legal or professional services, legal costs being on a substantial indemnity basis), proceedings, demands and charges whether arising under statute, contract or at common law, except Indirect Losses.