Treatment of Contribution Sample Clauses

Treatment of Contribution. The Parties intend that the contribution of the Shares and the receipt of the Units pursuant to this Agreement shall be tax free transactions governed by Section 721 of the Code. Each party agrees that it shall not take any position that is inconsistent with the foregoing in any filing made by such party with the IRS or any other taxing authority.
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Treatment of Contribution. The transfer of the Assets by Contributing Member (i) to the extent exchanged for an interest in the Venture shall be reported by the parties hereto as governed by Section 721(a) of the Code and (ii) to the extent exchanged for any consideration other than an interest in the Venture shall be reported by the parties as governed by Section 1001 and Section 1012. The provisions of this Section 2.6 shall survive the Contribution Date. The Venture shall allocate pursuant to Treasury Regulation ss. 1.163-8T the maximum amount of the proceeds of the New Debt to the repayment of the Existing Financing, Transaction Expenses, and the funding of Venture reserves or any other Venture item other than distributions to the Contributing Member under Section 5.5 of the Venture Agreement.
Sample 1
Treatment of Contribution. The transfer of the Assets by Contributing Member (a) to the extent exchanged for an interest in the Venture shall be reported by the parties hereto as governed by Section 721(a) of the Code and (b) to the extent exchanged for any consideration other than an interest in the Venture shall be reported by the parties as governed by Section 1001 and Section 1012.
Sample 1
Treatment of Contribution. The contributions and conveyances described in this Section 2.1 will be treated by the parties as a contribution, on behalf of and to the credit of Watco Mechanical and Millennium as set forth in the LLC Agreement of the Joint Venture, of the Watco Contributed Assets to the Joint Venture in exchange for the interests in the Joint Venture, pursuant to Section 721 of the Code and the Treasury Regulations promulgated thereunder.
Sample 1
Treatment of Contribution. The contributions and conveyances described in this Section 2.2 will be treated by the parties as contributions, on behalf of and to the credit of Greenbrier Rail Services Holdings, LLC as set forth in the LLC Agreement of the Joint Venture, of the Greenbrier Contributed Assets and the Shares to the Joint Venture in exchange for the interests in the Joint Venture, pursuant to Section 721 of the Code and the Treasury Regulations promulgated thereunder.
Sample 1

Related to Treatment of Contribution

  • Payment of Contributions The University and eligible academic staff members shall each contribute one-half of the contributions to the Academic and Administrative Pension Plan.

  • Investment of Contributions At the direction of the Depositor (or the direction of the beneficiary upon the Depositor's death), the Custodian shall invest all contributions to the account and earnings thereon in investments acceptable to the Custodian, which may include marketable securities traded on a recognized exchange or "over the counter" (excluding any securities issued by the Custodian), covered call options, certificates of deposit, and other investments to which the Custodian consents, in such amounts as are specifically selected and specified by the Depositor in orders to the Custodian in such form as may be acceptable to the Custodian, without any duty to diversify and without regard to whether such property is authorized by the laws of any jurisdiction as a trust investment. The Custodian shall be responsible for the execution of such orders and for maintaining adequate records thereof. However, if any such orders are not received as required, or, if received, are unclear in the opinion of the Custodian, all or a portion of the contribution may be held uninvested without liability for loss of income or appreciation, and without liability for interest pending receipt of such orders or clarification, or the contribution may be returned. The Custodian may, but need not, establish programs under which cash deposits in excess of a minimum set by it will be periodically and automatically invested in interest-bearing investment funds. The Custodian shall have no duty other than to follow the written investment directions of the Depositor, and shall be under no duty to question said instructions and shall not be liable for any investment losses sustained by the Depositor.

  • Allocation of Contributions You may place your contributions in one fund or in any combination of funds, although your employer may place restrictions on investment in certain funds.

  • Right of Contribution Each Guarantor hereby agrees that to the extent that a Guarantor shall have paid more than its proportionate share of any payment made hereunder, such Guarantor shall be entitled to seek and receive contribution from and against any other Guarantor hereunder which has not paid its proportionate share of such payment. Each Guarantor’s right of contribution shall be subject to the terms and conditions of Section 2.3. The provisions of this Section 2.2 shall in no respect limit the obligations and liabilities of any Guarantor to the Administrative Agent and the Lenders, and each Guarantor shall remain liable to the Administrative Agent and the Lenders for the full amount guaranteed by such Guarantor hereunder.

  • Form of Contribution The contribution of a member to the Company must be in cash or property, provided that if there is more than one member, all member(s) must consent in writing to contributions of property. To the extent there is more than one member, additional contributions in the same proportion shall be made by each member, except as may be approved by all member(s). A capital account shall be maintained for each member, to which contributions and profits shall be credited and against which distributions and losses shall be charged. At any time that there is more than one member, capital accounts shall be maintained in accordance with the tax accounting principles prescribed by the Treasury Regulations promulgated under Code Section 704 (the "Allocation Regulations"), so that the tax allocations provided in this Agreement shall, to the extent possible, have "substantial economic effect" within the meaning of the Allocation Regulations, or, if such allocations cannot have substantial economic effect, so that they may be deemed to be "in accordance with the member(s') interests in the Company" within the meaning of the Allocation Regulations.

  • Rights of Contribution The Guarantors agree among themselves that, in connection with payments made hereunder, each Guarantor shall have contribution rights against the other Guarantors as permitted under applicable law. Such contribution rights shall be subordinate and subject in right of payment to the obligations of such Guarantors under the Loan Documents and no Guarantor shall exercise such rights of contribution until all Obligations have been paid in full and the Commitments have terminated.

  • Return of Contributions The General Partner shall not be personally liable for, and shall have no obligation to contribute or loan any monies or property to the Partnership to enable it to effectuate, the return of the Capital Contributions of the Limited Partners or Unitholders, or any portion thereof, it being expressly understood that any such return shall be made solely from Partnership assets.

  • The Contribution Prior to the Effective Time, and subject to the terms and conditions set forth in the Distribution Agreement, Grace intends to cause the transfer to a wholly owned subsidiary of Grace-Conn. ("Packco") of certain assets and liabilities of Grace and its subsidiaries predominantly related to the Packaging Business (the "Contribution"), as contemplated by the Distribution Agreement and the Other Agreements.

  • Catch-Up Contributions In the case of a Traditional IRA Owner who is age 50 or older by the close of the taxable year, the annual cash contribution limit is increased by $1,000 for any taxable year beginning in 2006 and years thereafter.

  • Tax Credit for Contributions You may be eligible to receive a tax credit for your IRA contributions. This credit will be allowed in addition to any tax deduction that may apply, and may not exceed $1,000 in a given year. You may be eligible for this tax credit if you are • age 18 or older as of the close of the taxable year, • not a dependent of another taxpayer, and • not a full-time student. The credit is based upon your income (see chart below), and will range from 0 to 50 percent of eligible contributions. In order to determine the amount of your contributions, add all of the contributions made to your IRA and reduce these contributions by any distributions that you have taken during the testing period. The testing period begins two years prior to the year for which the credit is sought and ends on the tax return due date (including extensions) for the year for which the credit is sought. In order to determine your tax credit, multiply the applicable percentage from the chart below by the amount of your contributions that do not exceed $2,000. *Adjusted gross income (AGI) includes foreign earned income and income from Guam, America Samoa, North Mariana Islands, and Puerto Rico. AGI limits are subject to cost-of-living adjustments each year.