Treatment for Tax Purposes. It is the intention of the parties that, for U.S. Federal, state and local income and franchise tax purposes, the Transactions constitute a financing, and that the Seller is, and, so long as no Event of Default shall have occurred and be continuing, will continue to be, treated as the owner of the Purchased Loans for such purposes. Unless prohibited by applicable law, Seller and Buyer agree to treat the Transactions as described in the preceding sentence on any and all filings with any U.S. Federal, state or local taxing authority.
Treatment for Tax Purposes. It is the intention of the Member that the Company be treated as an entity disregarded from its owner for federal, state and local income tax purposes.
Treatment for Tax Purposes. The group life insurance premium is covered by the provisions of Part II of the Danish Taxation of Pensions Act. Form of taxation: “Tax code 5 – Life insurance without right of deduction”.
Treatment for Tax Purposes. The Members hereby agree to disregard the Company as a separate entity for tax purposes.
Treatment for Tax Purposes. The Issuer shall treat the Notes as indebtedness of the Issuer and the Collateral as assets owned by the Issuer for purposes of all federal, state and local income taxes, unless and until otherwise required by an applicable taxing authority.
Treatment for Tax Purposes. For federal and applicable state and local income tax purposes, the Purchaser and Seller shall treat the Purchaser’s acquisition of the Acquired Interests as a sale and purchase of the assets of HoldCo and its Subsidiary.
Treatment for Tax Purposes. To the maximum extent permitted by Law, Developer shall be treated as the owner for federal income tax purposes of such portion of the Project for which Developer is not reimbursed its total capital improvement costs by the TMC Public Funds Payment or (if applicable) the Public Funds Payments. The payment of the TMC Public Funds Payment and (if applicable) the Public Funds Payments by TxDOT to Developer is reimbursement of the portion of Developer’s total capital improvement costs of the Project that are expended by Developer on behalf of, and for the benefit of, TxDOT and shall not be treated as compensation or consideration of any kind paid by TxDOT to Developer for federal income tax purposes. TxDOT will not file any documentation with the United States government inconsistent with this Section 2.5.
Treatment for Tax Purposes. For all applicable Tax purposes, each Party agrees to treat any indemnity payment under this Article VII as an adjustment to the Aggregate Closing Payment, unless otherwise required by applicable Law.
Treatment for Tax Purposes. For so long as the Company has only one member, it is the intention of the Member that the Company be disregarded as a separate entity for federal, state and local tax purposes. If at any time the Company has more than one member, it shall be treated as a partnership for federal, state and local tax purposes.
Treatment for Tax Purposes. To the extent permitted by law, the Parties agree, solely for Tax purposes, to treat all payments made under this Article VIII, under any other indemnity provision contained in this Agreement, and for any misrepresentations or breach of warranties or covenants, as adjustments to the Aggregate Purchase Price for all Tax purposes, except to the extent the Law of a particular jurisdiction provides otherwise.
