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Tax Treaty Sample Clauses

Tax Treaty. Each Lender that is organized under the laws of a country other than the United States of America agrees (a) on or before the date the first Advance is made, to complete and deliver to Borrowers Internal Revenue Service Form 4224, and (b) to complete and deliver to Borrowers from time to time, provided such Lender is eligible to do so, any successor or additional forms required in order to secure an exemption from, or reduction in the rate of, income tax withholding imposed by the United States of America. Each Lender shall amend or supplement any such form as required and permitted by applicable law to insure that it is in full force and effect, accurate and complete at all times.
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Tax Treaty. Holdings is a resident of the Netherlands within the meaning of Article 4 of the Convention between Venezuela and the Netherlands for the Avoidance of Double Taxation and Fiscal Evasion on Income and its Protocol (the “Convention”). Holdings does not have a permanent establishment in Venezuela within the meaning of Section 5 of the Convention. Holdings has received a residency certificate from the Netherlands sufficient under the Ley de Impuesto Sobre la Renta of Venezuela for purposes of receiving tax benefits pursuant to the Convention.
Sample 1
Tax Treaty. 14 Section 3.12 Brokers......................................................14
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Tax Treaty. The Lender is organized under the laws of the Kingdom of Norway and agrees: (a) To complete and deliver to the Borrowers on or before the first Drawdown Date Internal Revenue Service Form 4224. (b) To complete and deliver to the Borrowers from time to time, provided the Lender is eligible to do so, any successor or additional forms required in order to secure an exemption from, or reduction in the rate of, income tax withholding imposed by the United States of America. The Lender shall amend or supplement any such form as required and permitted by applicable law to insure that it is in full force and effect, accurate and complete at all times.
Sample 1
Tax Treaty. The Lender is organized under the laws of the Kingdom of Norway and agrees: (a) To complete and deliver to the Borrowers on or before the first Drawdown Date Internal Revenue Service Form 4224. [THIS PORTION INTENTIONALLY LEFT BLANK] (b) To complete and deliver to the Borrowers from time to time, provided the Lender is eligible to do so, any successor or additional forms required in order to secure an exemption from, or reduction in the rate of, income tax withholding imposed by the United States of America. The Lender shall amend or supplement any such form as required and permitted by applicable law to insure that it is in full force and effect, accurate and complete at all times.
Sample 1
Tax Treaty. If so required by law IMagic may deduct from the amount due to be paid pursuant to this Agreement a withholding tax of not more than 5 per cent pursuant to the US-France Income Tax Convention, provided IMagic provides a copy of any payment stub and official tax receipt demonstrating that such withholding tax has been paid to the U.S. and State taxation authorities and provided further that if Ubi Soft is unable to use the tax credit to its fullest extent, then IMagic shall immediately pay the balance required to gross up the relevant payment so that the net amount received by Ubi Soft is not less than the gross amount due.
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Tax Treaty. 27 Section 8. Security........................................................ 28
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Tax Treaty. Itochu and Converse acknowledge that this Agreement is a ----------- sale for the purposes of Articles 14 and 16 of the United States/Japan Tax treaty.
Sample 1
Tax Treaty. Each Lender organized under the laws of a jurisdiction outside the United States (a "Foreign Lender") as to which payments to be made under this Credit Agreement or under the Notes are exempt from United States withholding tax under an applicable statute or tax treaty shall provide to the Borrower and the Agent a properly completed and executed IRS Form 4224 or Form 1001 or other applicable form, certificate or document prescribed by the IRS or the United States certifying as to such Foreign Lender's entitlement to such exemption (a "Certificate of Exemption"). Any foreign Person that seeks to become a Lender under this Agreement shall provide a Certificate of Exemption to the Borrower and the Agent prior to becoming a Lender hereunder. No foreign Person may become a Lender hereunder if such Person is unable to deliver a Certificate of Exemption.
Sample 1

Related to Tax Treaty

  • Tax Treatment If any interest in any Loan Document is transferred to any Transferee which is organized under the laws of any jurisdiction other than the United States or any State thereof, the transferor Lender shall cause such Transferee, concurrently with the effectiveness of such transfer, to comply with the provisions of Section 3.5(iv).

  • Income Tax Treatment Employee and the Company acknowledge that it is the intention of the Company to deduct all amounts paid under Section 2 hereof as ordinary and necessary business expenses for income tax purposes. Employee agrees and represents that he will treat all such amounts as required pursuant to all applicable tax laws and regulations, and should he fail to report such amounts as required, he will indemnify and hold the Company harmless from and against any and all taxes, penalties, interest, costs and expenses, including reasonable attorneys' and accounting fees and costs, which are incurred by Company directly or indirectly as a result thereof.

  • Intended Tax Treatment Notwithstanding anything to the contrary herein or in any other Transaction Document, all parties to this Agreement covenant and agree to treat each Loan under this Agreement as debt (and all Interest as interest) for all federal, state, local and franchise tax purposes and agree not to take any position on any tax return inconsistent with the foregoing.

  • Agreed Tax Treatment Each Security issued hereunder shall provide that the Company and, by its acceptance or acquisition of a Security or a beneficial interest therein, the Holder of, and any Person that acquires a direct or indirect beneficial interest in, such Security, intend and agree to treat such Security as indebtedness of the Company for United States Federal, state and local tax purposes and to treat the Preferred Securities (including but not limited to all payments and proceeds with respect to the Preferred Securities) as an undivided beneficial ownership interest in the Securities (and payments and proceeds therefrom, respectively) for United States Federal, state and local tax purposes. The provisions of this Indenture shall be interpreted to further this intention and agreement of the parties.

  • Special Tax Treatment Capital gains treatment and 10-year forward income averaging authorized by IRC Sec. 402 do not apply to IRA distributions.

  • Tax Ruling The Assuming Institution shall not at any time, without the Receiver’s prior written consent, seek a private letter ruling or other determination from the Internal Revenue Service or otherwise seek to qualify for any special tax treatment or benefits associated with any payments made by the Receiver pursuant to this Single Family Shared-Loss Agreement.

  • Federal Income Tax Treatment It is the intention of the Trust Depositor that the Trust be disregarded as a separate entity pursuant to Treasury Regulations Section 301.7701-3(b)(1)(ii) as in effect for periods after January 1, 1997. The Trust Certificate constitutes the sole equity interest in the Trust and must at all times be held by either the Trust Depositor or its transferee as sole owner. The Trust Depositor agrees not to take any action inconsistent with such intended federal income tax treatment. Because for federal income tax purposes the Trust will be disregarded as a separate entity, Trust items of income, gain, loss and deduction for any month as determined for federal income tax purposes shall be allocated entirely to the Trust Depositor (or subsequent purchaser of the Trust Certificate) as the sole Certificateholder.

  • Tax Treatment of Indemnity Payments Seller and Buyer agree to treat any indemnity payment made pursuant to this Article X as an adjustment to the Purchase Price for Tax purposes.

  • Tax Treatment of Payments Except to the extent otherwise required pursuant to a “determination” (within the meaning of Section 1313(a) of the Code or any similar provision of state, local or foreign Law), Seller, Purchaser, the Company and their respective Affiliates shall treat any and all payments under this Article ‎VII, Section ‎‎2.7 and ‎Article ‎X as an adjustment to the Purchase Price for Tax purposes.

  • Tax Rulings Neither the Company nor any of its Subsidiaries has requested or is the subject of or bound by any private letter ruling, technical advice memorandum, or similar ruling or memorandum with any taxing authority with respect to any material Taxes, nor is any such request outstanding.

Most Referenced Clauses

Most Referenced Definitions