BIG Tax definition

BIG Tax shall have the meaning set forth in Section 10.5(d).
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BIG Tax has the meaning set forth in Section 5.3.
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BIG Tax has the meaning set forth in Section 11.1.
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Examples of BIG Tax in a sentence

  • For purposes hereof, the BIG Tax shall be calculated based on the maximum combined effective U.S. federal, state, and local tax rate applicable to an individual resident of New York, New York, such rate determined at the time of the Pre-Closing.

  • Notwithstanding anything to the contrary contained in this Section, the Stockholders and Buyer shall each bear and pay 50% of all filing fees required to be paid under the HSR Act, in connection with the transactions contemplated hereby and, in accordance with Section 8.2, Buyer shall pay the fees of Buyer's and SRC's consultants relating to the determination of any built in gains tax or any BIG Tax Benefit, including the cost of any appraisal work commissioned and/or authorized by Buyer.

  • INADEQUATE TAX BASIS: NAVIGATING NEW IRS REGULATIONS FOR S CORPORATIONS Norman Lencz, Venable LLPnlencz@Venable.comChris Davidson, Venable LLPcsdavidson@Venable.com January 6, 2015 Background - S Corporation Taxation  “Pass-through” entity. In general, taxed only at shareholder level.• Exceptions: BIG Tax and Passive Income Tax. S corporation reports its taxable income on Form 1120-S. Issues K-1s to shareholders who then pick up their share of taxable income or loss and pay taxes on such income.

  • At issue in this case was not the applicability of the BIG Tax discount, but the magnitude of the discount.

  • Any BIG Tax is and shall remain the obligation of the Corporation and the Buyer shall cause the Corporation to timely satisfy such obligation without contribution from, or indemnification by, the Shareholders.

  • Most frequently, this is seen in the context of a closely held corporation which owns stock or other capital assets (a “holding company”) where the corporation’s value is premised on asset value (which lends itself to application of a discount for the contingent BIG Tax liability).

  • Tax Court-­‐-­‐TC Memo 2005-­‐131 (May 31, 2004)Tax Court Rejects Dunn and Allows Discount Equal to 41 Percent of BIG Tax, See 2b, below, for 11th Circuit Decision Commercial Chemical Co. ("CCC") was incorporated in the 1920's and operated a chemical manufacturing business until it sold the business assets in 1974.

  • Accordingly, the Court held that the full amount of the BIG Tax would be allowed as a discount from the value of the corporation.

  • Conceptually, a buyer would be just as concerned with the BIG Tax in an S-­‐corporation as in a C-­‐corporation (as there is no inside basis step-­‐up for an S-­‐corporation’s basis in its assets (as there is in a partnership), any future sale or liquidation of those assets is going to trigger tax to the shareholders).

  • SRC has paid any corporate level Taxes required to be paid by SRC in respect of all periods on or prior to the Closing Date that were due and payable on or prior to the Closing Date with the exception of the federal BIG Tax and any corporate level state taxes accrued in the normal course of SRC's business (without regard to the Election).


More Definitions of BIG Tax

BIG Tax means the product of the corporate Assumed Tax Rate and BIG.
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Related to BIG Tax

  • Income Tax means any federal, state, local, or foreign income tax, including any interest, penalty, or addition thereto, whether disputed or not.

  • input tax , in relation to a vendor, means—

  • Withholding Tax means any tax, deduction, levy or similar payment obligation that is required to be deducted or withheld from a payment under Applicable Law.

  • Use tax means a nonrecurring tax, other than a sales tax, which (a) is imposed on or with respect to the exercise or enjoyment of any right or power over tangible personal property incident to the ownership, possession or custody of that property or the leasing of that property from another including any consumption, keeping, retention, or other use of tangible personal property and (b) is complementary to a sales tax.

  • FATCA Withholding Tax means any U.S. federal withholding tax imposed or collected pursuant to Sections 1471 through 1474 of the Code, any current or future regulations or official interpretations thereof, any agreement entered into pursuant to Section 1471(b) of the Code, or any fiscal or regulatory legislation, rules or practices adopted pursuant to any intergovernmental agreement entered into in connection with the implementation of such Sections of the Code.

  • Swiss Federal Tax Administration means the tax authorities referred to in article 34 of the Swiss Withholding Tax Act.

  • council tax benefit means council tax benefit under Part 7 of the SSCBA; “couple” has the meaning given by paragraph 4;

  • central tax means the central goods and services tax levied under section 9 of the Central Goods and Services Tax Act;

  • School operating taxes means local ad valorem property taxes levied under section 1211 of the revised school code, MCL 380.1211, and retained for school operating purposes.

  • Australian Tax Act means the Income Tax Assessment Act 1936 (Cth) (Australia) or the Income Tax Assessment Act 1997 (Cth) (Australia), as applicable.

  • VAT Group means a group for the purposes of the VAT Grouping Legislation.

  • Federal Tax means any Tax imposed under Subtitle A of the Code.

  • VAT means value added tax.

  • taxable trading means carrying on a trade or business for the principal purpose of raising funds and not for the purpose of actually carrying out the Objects, the profits of which are subject to corporation tax;

  • REO Tax As defined in Section 3.17(a).

  • value added tax means value added tax charged in accordance with the Value Added Tax Act 1994.

  • Tax roll means a permanent record of the taxes charged on property, as extended

  • Goods and Services Tax (GST) shall mean any tax payable on the supply of goods, services or other things in accordance with the provisions of GST Law.

  • Relevant Tax Authority means HMRC, or, if applicable, the tax authority in the jurisdiction in which the Supplier is established;

  • Qualifying tax rate means the applicable tax rate for the taxable year for the which the taxpayer paid income tax to a municipal corporation with respect to any portion of the total amount of compensation the payment of which is deferred pursuant to a nonqualified deferred compensation plan. If different tax rates applied for different taxable years, then the “qualifying tax rate” is a weighted average of those different tax rates. The weighted average shall be based upon the tax paid to the municipal corporation each year with respect to the nonqualified deferred compensation plan.

  • Post-Closing Tax Period means any Tax period (or portion thereof) beginning after the Closing Date.

  • After-imposed Federal tax means any new or increased Federal excise tax or duty, or tax that was exempted or excluded on the contract date but whose exemption was later revoked or reduced during the contract period, on the transactions or property covered by this contract that the Contractor is required to pay or bear as the result of legislative, judicial, or administrative action taking effect after the contract date. It does not include social security tax or other employment taxes.

  • GST/HST means all goods and services tax and harmonized sales tax imposed under Part IX of the Excise Tax Act (Canada).

  • Relevant Tax means any present or future taxes, duties, assessments or governmental charges of whatever nature, imposed or levied by or on behalf of any Relevant Jurisdiction or any authority therein or thereof having the power to tax.

  • Tax means any tax, levy, impost, duty or other charge or withholding of a similar nature (including any penalty or interest payable in connection with any failure to pay or any delay in paying any of the same).

  • Sales Tax means all applicable provincial and federal sales, use, value-added or goods and services taxes, including GST/HST;