Section 951(a) Income Definition - Law Insider

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Section 951(a) Income definitionSection 951(a) Income means income includable in the gross income of the Parent (or any member of the consolidated group of which the Parent is the common parent) for U.S. federal income tax purposes pursuant to Section 951(a) of the Code, as a result of the operations of the Company and its Subsidiaries after December 31, 2005; provided that any such income includable in the gross income of the Parent (or any member of the consolidated group of which the Parent is the common parent) that is attributable to the operations of any Excluded Subsidiaries (unless cash distributions in an amount equal to such income are received by the Company or any other Loan Party from such Excluded Subsidiary solely for purposes of making Tax Distributions) shall not constitute Section 951(a) Income.View SourceBased on 2 documents2Microsoft® Word Add-inDraft with AIsparksSplit ViewAI-Powered Contracts

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Examples of Section 951(a) Income in a sentence

  • The Company shall use commercially reasonable efforts to minimize the Section 951(a) Income generated by the operations of the Loan Parties.

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