Examples of Tax Blocker Subsidiaries in a sentence
It shall not have or permit the formation of any subsidiaries, except (i) in connection with the receipt of equity securities with respect to a Collateral Loan, an Eligible Investment or any exchange offer, work-out or restructuring of a Collateral Loan or (ii) Tax Blocker Subsidiaries.
The Tax Blocker Subsidiaries must be separate entities taxed under Subchapter C of the Code in order to serve their income blocking purpose.
The Borrower has no Subsidiaries except Tax Blocker Subsidiaries not otherwise prohibited hereunder.
The Tax Blocker Subsidiaries exist solely for the benefit of Fifth Street in order to hold Fifth Street’s interests in its portfolio companies and do not provide any services to any other company.
It shall not have or permit the formation of any subsidiaries, except (i) in connection with the receipt of equity securities with respect to a Collateral Loan or Eligible Investments or (ii) Tax Blocker Subsidiaries.
Fifth Street utilizes the Tax Blocker Subsidiaries to hold Fifth Street’s interests in certain of Fifth Street’s portfolio companies.
These Tax Blocker Subsidiaries are structured as corporations in order to block operating income from investment portfolio companies (structured as limited liability companies or limited partnerships) held in the Tax Blocker Subsidiaries from passing through to Fifth Street.
Fifth Street makes, and will continue to make, available significant managerial assistance to the issuers of securities held by Tax Blocker Subsidiaries to the extent required by Section 2(a)(48)(B).3 iii.
Form, create, organize, acquire or otherwise have any Subsidiaries other than Tax Blocker Subsidiaries.
The Tax Blocker Subsidiaries exist now, and any such entities created in the future would exist, to enhance the opportunity for Fifth Street to elect RIC status under the Code, which benefits investors since companies electing that status are not liable for federal income tax at the corporate level.Perhaps most importantly, the assets of the Subsidiaries are recorded on Fifth Street’s balance sheet, and thus considered assets of Fifth Street for GAAP purposes.