BBA Rules definition
Examples of BBA Rules in a sentence
Notwithstanding any provision to the contrary in this Agreement, the Partnership Representative shall be permitted make an election under Section 6226 of the BBA Rules (and any similar provision of state, local and non-U.S. tax Law) with respect to any Audit.
References to Code Sections in this paragraph are to such provisions as amended by the BBA Rules.
The General Partner shall be the “tax matters partner” of the Partnership for purposes of the TEFRA Rules and the “partnership representative” of the Partnership for purposes of the BBA Rules (collectively, the “tax matters partner”) for federal income tax purposes.
The Partners acknowledge and agree that the General Partner and Partnership Representative shall be permitted, but not required, to take any actions to reduce or avoid Entity Taxes being imposed on the Partnership or any of its subsidiaries or investments under the BBA Rules.
If the Partnership Representative is not the General Partner, the Partnership Representative shall consult with the General Partner as to how to conduct any material administrative and judicial proceedings or whether to make any election under the BBA Rules, including the election under Section 6226 of the Internal Revenue Code.