Attributable is defined in Section 3.1(b)(i) of this Agreement.
Attributable means, with respect to any Applicable Member, the portion of any Realized Tax Benefit of the Corporate Taxpayer that is “attributable” to such Applicable Member, which shall be determined by reference to the assets from which arise the depreciation, amortization or other similar deductions for recovery of cost or basis (“Depreciation”) and with respect to increased basis upon a disposition of an asset or Imputed Interest that produce the Realized Tax Benefit, under the following principles:
Attributable is defined in Section 3.1(b)(i).
Examples of Attributable in a sentence
Within five (5) Business Days after a Tax Benefit Schedule delivered to a TRA Party and the TRA Party Representative becomes final in accordance with Section 2.3(a) and Section 7.9, if applicable, PubCo shall pay such TRA Party for such Taxable Year the Tax Benefit Payment determined pursuant to Section 3.1(b) that is Attributable to the such TRA Party.
Any Tax Benefit Payments attributable to the Exchange Basis or Blocker Transferred Basis are intended to be Attributable to, and allocated and paid to, the relevant TRA Parties based on the Previously Taxed Capital delivered by such TRA Party in the applicable Exchange or in the Reorganization.
More Definitions of Attributable
Attributable means the portion of any Tax Attribute of the Corporate Taxpayer that is attributable to a TRA Party and shall be determined by reference to the Tax Attributes, under the following principles:
Attributable. The portion of any Realized Tax Benefit of the Corporation that is “Attributable” to any present or former Partner other than the Corporation shall be determined by reference to the assets from which arise the depreciation, amortization or other similar deductions for recovery of cost or basis (“Depreciation”) and with respect to Imputed Interest that produce the Realized Tax Benefit, under the following principles:
Attributable means attributable on a just and reasonable basis.
Attributable means the portion of any Tax Attribute of the Corporate Taxpayer that is “Attributable” to any present or former Unit Holder, as the case may be, determined under the following principles:
Attributable in this context means “capable of being attributed to”, in the sense of being a real possibility;
Attributable means that it should be clear who has created, updated or amended a particular record.
Attributable means the portion of any Tax Attribute of the Corporate Taxpayer that is “Attributable” to the Blocker Shareholders and shall be determined by reference to the Tax Attributes, under the following principles: