Examples of US Sub in a sentence
Notwithstanding the foregoing, so long as You have complied with the the IP Restriction, the Subsidiary Cash Cap and the Receivables Restriction, and provided that the US Sub’s only assets are the equity interest of a direct Foreign Subsidiary and de minimus assets incidental thereto, You shall only be required to provide a pledge for sixty-five percent (65%) of the voting equity interest in the US Sub.
The OMUSH shares were transferred to U.K. Sub via a series of share exchanges, and the new intercompany debt was contributed among OMAM, U.S. Sub and U.K. Sub.
Accordingly, we expect Parent Co to take the position that it is entitled to a positive basis adjustment of $ee in its US Sub stock.
The commission has 28 members from North and Central America, Asia, Europe, and Africa with leadership experience in business, banking, policy research, government, academia, nongovernmental organi- zations, and international institutions.The commission was launched in September 2002 and has held seven meetings in Washington, DC, and New York City as well as a briefing session at the US Sub- Saharan Africa Trade and Economic Cooperation [AGOA] Forum in Mauritius in January 2003.
Id. If US Sub is treated as redeeming Parent Co’s Excess Value US Sub common stock, the result would be the same.
That results in two different treatments for the income US Sub recognizes from the exchange.
Thus, the approach of applying § 351(b) first results in this case in US Sub recognizing two very different types of income on the same transfer: domestic source capital gain with respect to gain from the boot and foreign source ordinary income with respect to the remaining value of the IP.
With the Note recast as equity, the payments from U.S. Sub to FP are recast as dividend distributions and are therefore not deductible to U.S. Sub.
The Options shall be subject to the terms of the Parent’s 2012 Equity Incentive Plan and the 2012 U.S. Sub Plan thereto, as may be amended from time to time, or any successor plans, and an Option Agreement to be executed between Parent and the Employee.
As noted above, Parent Co indicated in its Protest that US Sub distributed the Parent Co Note back to Parent Co so that the Parent Co Note was extinguished.