Treatment of StadCo Contribution Amount Sample Clauses

Treatment of StadCo Contribution Amount. The Parties agree and acknowledge that, for all federal and applicable state and local income tax purposes, but only for those purposes, (a) the StadCo Contribution Amount, and any amounts expended by StadCo pursuant to Article 7 (
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Treatment of StadCo Contribution Amount. The Parties agree and acknowledge that, for all federal and applicable state and local income tax purposes, but only for those purposes, (a) the StadCo Contribution Amount shall be treated as prepaid rent paid by StadCo to the Authority and (b) the aggregate amount of that prepaid rent shall be allocated for purposes of Treasury Regulations Section 1.467-1(c)(2)(ii) in equal annual installments (prorated for partial calendar years) to each year during the term of this Agreement (determined by assuming that the Agreement does not terminate early in accordance with clause (ii) of the definition of Term Expiration Date). For each year during the foregoing term, solely for federal and applicable state and local income tax purposes, StadCo shall accrue interest income and the Authority shall accrue corresponding interest expense on the resulting “section 467 loan” in accordance with the principles of Treasury Regulations Section 1.467-4. Any such interest shall be taken into account in determining the balance of such a “section 467 loan”, but in no event shall any principal or interest on such a “section 467 loan” be separately payable (including upon any termination of this Agreement).
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Treatment of StadCo Contribution Amount. The Parties agree and acknowledge that, for all federal and applicable state and local income tax purposes, but only for those purposes and without implication for any other provision of this Agreement, (a) to the extent the Stadium or any other Improvements are funded by StadCo as Project Improvements Work or pursuant to Article 7 (
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Treatment of StadCo Contribution Amount. The Parties agree and acknowledge that, for all federal and applicable state and local income tax purposes, but only for those purposes, (a) the StadCo Contribution Amount, and any amounts expended by StadCo pursuant to Article 7 or 8 of this Lease shall be treated as prepaid rent paid by StadCo to the Authority and (b) the aggregate amount of that prepaid rent shall be allocated for purposes of Treasury Regulations Section 1.467-1(c)(2)(ii) in equal annual installments (prorated for partial calendar years) to each year during the term of this Agreement (determined by assuming that the Agreement does not terminate early in accordance with clause (ii) of the definition of Term Expiration Date). For each year during the foregoing term, solely for federal and applicable state and local income tax purposes, StadCo shall accrue interest income and the Authority shall accrue corresponding interest expense on the resulting “section 467 loan” in accordance with the principles of Treasury Regulations Section 1.467-4. Any such interest shall be taken into account in determining the balance of such a “section 467 loan”, but in no event shall any principal or interest on such a “section 467 loan” be separately payable (including upon any termination of this Agreement).1
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Related to Treatment of StadCo Contribution Amount

  • Contribution Amounts The Sellers and the Underwriters agree that it would not be just or equitable if contribution pursuant to this Section 8 were determined by pro rata allocation (even if the Underwriters were treated as one entity for such purpose) or by any other method of allocation that does not take account of the equitable considerations referred to in Section 8(h). The amount paid or payable by an indemnified party as a result of the losses, claims, damages and liabilities referred to in the immediately preceding paragraph shall be deemed to include, subject to the limitations set forth above, any legal or other expenses reasonably incurred by such indemnified party in connection with investigating or defending any such action or claim. Notwithstanding the provisions of this Section 8, no Underwriter shall be required to contribute any amount in excess of the amount by which the total price at which the Shares underwritten by it and distributed to the public were offered to the public exceeds the amount of any damages that such Underwriter has otherwise been required to pay by reason of such untrue or alleged untrue statement or omission or alleged omission. No person guilty of fraudulent misrepresentation (within the meaning of Section 11(f) of the Securities Act) shall be entitled to contribution from any person who was not guilty of such fraudulent misrepresentation. The remedies provided for in this Section 8 are not exclusive and shall not limit any rights or remedies which may otherwise be available to any indemnified party at law or in equity.

  • How Are Contributions to a Xxxx XXX Reported for Federal Tax Purposes You must file Form 5329 with the IRS to report and remit any penalties or excise taxes. In addition, certain contribution and distribution information must be reported to the IRS on Form 8606 (as an attachment to your federal income tax return.)

  • Distribution of Financial Contribution The financial contribution of the Funding Authority to the Project shall be distributed by the Coordinator according to: - the Consortium Plan - the approval of reports by the Funding Authority, and - the provisions of payment in Section 7.3. A Party shall be funded only for its tasks carried out in accordance with the Consortium Plan.

  • 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.

  • Return of Contribution Nonrecourse to Other Members Except as provided by law, upon dissolution, each member shall look solely to the assets of the Company for the return of the member's capital contribution. If the Company property remaining after the payment or discharge of the Company's debts and liabilities is insufficient to return the cash contribution of one or more members, such member or members shall have no recourse against any other member or the Board.

  • What Forms of Distribution Are Available from a Xxxxxxxxx Education Savings Account Distributions may be made as a lump sum of the entire account, or distributions of a portion of the account may be made as requested.

  • Adjustment of Minimum Quarterly Distribution and Target Distribution Levels (a) The Minimum Quarterly Distribution, First Target Distribution, Second Target Distribution, Third Target Distribution, Common Unit Arrearages and Cumulative Common Unit Arrearages shall be proportionately adjusted in the event of any distribution, combination or subdivision (whether effected by a distribution payable in Units or otherwise) of Units or other Partnership Securities in accordance with Section 5.10. In the event of a distribution of Available Cash that is deemed to be from Capital Surplus, the then applicable Minimum Quarterly Distribution, First Target Distribution, Second Target Distribution and Third Target Distribution, shall be adjusted proportionately downward to equal the product obtained by multiplying the otherwise applicable Minimum Quarterly Distribution, First Target Distribution, Second Target Distribution and Third Target Distribution, as the case may be, by a fraction of which the numerator is the Unrecovered Capital of the Common Units immediately after giving effect to such distribution and of which the denominator is the Unrecovered Capital of the Common Units immediately prior to giving effect to such distribution. (b) The Minimum Quarterly Distribution, First Target Distribution, Second Target Distribution and Third Target Distribution, shall also be subject to adjustment pursuant to Section 6.9.

  • Contribution Allocation The Advisory Committee will allocate deferral contributions, matching contributions, qualified nonelective contributions and nonelective contributions in accordance with Section 14.06 and the elections under this Adoption Agreement Section 3.04. PART I. [OPTIONS (a) THROUGH (d)].

  • Deemed Distribution and Recontribution Notwithstanding any other provision of this Article 13, in the event the Partnership is liquidated within the meaning of Regulations Section 1.704-1(b)(2)(ii)(g) but no Liquidating Event has occurred, the Partnership's property shall not be liquidated, the Partnership's liabilities shall not be paid or discharged, and the Partnership's affairs shall not be wound up. Instead, the Partnership shall be deemed to have distributed the Partnership property in kind to the General Partner and Limited Partners, who shall be deemed to have assumed and taken such property subject to all Partnership liabilities, all in accordance with their respective Capital Accounts. Immediately thereafter, the General Partner and Limited Partners shall be deemed to have recontributed the Partnership property in kind to the Partnership, which shall be deemed to have assumed and taken such property subject to all such liabilities.

  • Are There Penalties for Early Distribution from a Xxxx XXX As indicated above, earnings on your contributions, as well as amounts contributed to a Xxxx XXX as a rollover from a Traditional IRA, that are distributed before certain events are subject to various taxes. Please see IRS Publication 590 for further information about Xxxx XXX rules and restrictions.

Most Referenced Clauses

Most Referenced Definitions