Examples of Disregarded Subsidiary in a sentence
All Property Taxes levied (and refunds received) with respect to the Purchased Assets or the assets of any Disregarded Subsidiary Company for the Straddle Tax Period, and all contingent expenses paid to consultants for appealing such Property Taxes, shall be apportioned between Buyer and Seller based on the number of days of such Straddle Tax Period included in the Pre-Closing Tax Period and the number of days of such Straddle Tax Period included in the Post-Closing Tax Period.
Each Disregarded Subsidiary (other than Casino Computer Programming, Inc., an Indiana corporation (“CCPI”)) has been “disregarded as an entity separate from its owner” within the meaning of Treasury Regulation Section 301.7701-3(b)(ii) for federal Income Tax purposes at all times since its acquisition by the Company.
In the case of a Disregarded Subsidiary, for U.S. federal income tax purposes (i) the Fund is treated as owning the Disregarded Subsidiary’s assets directly; (ii) any income, gain, loss, deduction or other tax items arising in respect of the Disregarded Subsidiary’s assets will be treated as if they are realized or incurred, as applicable, directly by the Fund; and (iii) any distributions the Fund receives from the Disregarded Subsidiary will have no effect on the Fund’s U.S. federal income tax liability.
The Strategic Plan Financial Policies discussed in Section 3.1 provide some basic guidelines for financial planning.