Canadian Tax Elections definition

Canadian Tax Elections means any election under (i) Part IX of the Excise Tax Act (Canada), (ii) an Act respecting the Quebec sales tax, if relevant and applicable, (iii) subsection 20(24) of the Income Tax Act (Canada) (including any corresponding election as may be required under the laws of provincial application), if relevant and applicable, (iv) section 22 of the Income Tax Act (Canada) (including any corresponding election under the laws of provincial application), if relevant and applicable, and (v) section 56.4 of the Income Tax Act (Canada) at the request of Buyer or Seller, if relevant and applicable, in each case, to lawfully seek to minimize the Taxes payable (including by way of refund or credit) under the Applicable Laws of Canada with respect to the consummation of the sale of the Transferred Assets of Canadian Seller and the assumption of the Canadian Liabilities of Canadian Seller.
Canadian Tax Elections means elections filed by Mxxxxx Canada and Bxxxxx Canada under the Income Tax Act (Canada), Excise Tax Act (Canada), Corporations Tax Act (Ontario), and such other taxation statutes in Canada or the Province of Ontario in connection with the transfer of the Canadian Acquired Assets.
Canadian Tax Elections means any relevant and applicable election requested by Buyer under (i) Part IX of the Excise Tax Act (Canada), (ii) an Act respecting the Quebec sales tax, (iii) subsection 20(24) of the Tax Act (including any corresponding election as may be required under the laws of provincial application) (iv) section 22 of the Tax Act (including any corresponding election under the laws of provincial application), and (v) section 56.4 of the Tax Act, in each case, to lawfully seek to minimize the Taxes payable (including by way of refund or credit) with respect to the consummation of the sale of the Transferred Assets used in a business carried on by any Asset Seller in Canada.

Examples of Canadian Tax Elections in a sentence

  • Admission offers are contingent upon the successful completion of the student’s final year in high school.

  • Each party shall use commercially reasonable efforts to (i) avail itself of any available exemptions from, or any refunds, credits or other recovery of, any such Transfer Taxes or fees (including, if applicable, by making any Canadian Tax Elections) and shall cooperate with the other party in providing any information and documentation that may be necessary to obtain such exemptions, refunds, credits or other recovery and (ii) minimize the amount of any such Transfer Taxes.


More Definitions of Canadian Tax Elections

Canadian Tax Elections means any relevant and applicable election requested by Buyer under (i) Part IX of the Excise Tax Act (Canada), (ii) an Act respecting the Quebec sales tax, (iii) subsection 20(24) of the Tax Act (including any corresponding election as may be required under the laws of provincial application) (iv) section 22 of the Tax Act (including any corresponding election under the laws of provincial application), and (v) section 56.4 of the Tax Act, in each case, to lawfully seek to minimize the Taxes payable (including by way of refund or credit) with respect to the consummation of the sale of the Transferred Assets used in a business carried on by any Asset Seller in Canada.
Canadian Tax Elections means any election under (i) Section 167 of the Excise Tax Act (Canada), (ii) Section 75 and75.1 of An Act Respecting the Quebec Sales Tax, if relevant and applicable, (iii) subsection 20(24) of the Income Tax Act (Canada) (including any corresponding election as may be required under the laws of provincial application), if relevant and applicable, (iv) section 22 of the Income Tax Act (Canada) (including any corresponding election under the laws of provincial application), if relevant and applicable, and (v) section 56.4 of the Income Tax Act (Canada), if relevant and applicable, in each case, to lawfully seek to minimize the Taxes payable (including by way of refund or credit) under the Applicable Laws of Canada with respect to the consummation of the sale of the Transferred Assets of Canadian Seller and the assumption of the Canadian Liabilities of Canadian Seller.

Related to Canadian Tax Elections

  • Income Tax Returns mean all Tax Returns that relate to Income Taxes.

  • Income Tax Return means any return, declaration, report, claim for refund, or information return or statement relating to Income Taxes, including any schedule or attachment thereto, and including any amendment thereof.

  • Non-Income Tax Return means any Tax Return relating to any Tax other than an Income Tax.

  • Combined Tax Return means a Tax Return filed in respect of U.S. federal, state, local or non-U.S. income Taxes for a Combined Group, or any other affiliated, consolidated, combined, unitary, fiscal unity or other group basis (including as permitted by Section 1501 of the Code) Tax Return of a Combined Group.

  • Canadian Tax Act means the Income Tax Act (Canada) and the regulations thereunder, as amended from time to time.

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

  • Tax Return means any return, declaration, report, claim for refund, or information return or statement relating to Taxes, including any schedule or attachment thereto, and including any amendment thereof.

  • Hypothetical Tax Liability means, with respect to any Taxable Year, the liability for Taxes of the Corporation (or the Partnerships, but only with respect to Taxes imposed on the Partnerships and allocable to the Corporation) using the same methods, elections, conventions and similar practices used on the relevant Corporation Return but using the Non-Stepped Up Tax Basis instead of the tax basis reflecting the Basis Adjustments of the Adjusted Assets and excluding any deduction attributable to Imputed Interest.

  • Canadian Taxes has the meaning specified in Section 1005.

  • Payroll Taxes means State Unemployment Insurance (SUI), Federal Unemployment Insurance (FUI), and payments pursuant to the Federal Insurance Contributions Act (FICA).

  • Consolidated federal income tax return means a consolidated return filed for federal income tax purposes pursuant to section 1501 of the Internal Revenue Code.

  • Assumed Tax Liability means, with respect to any Member, an amount equal to the excess of (i) the product of (A) the Distribution Tax Rate multiplied by (B) the estimated or actual cumulative taxable income or gain of the Company, as determined for federal income tax purposes, allocated to such Member (or its predecessor) for full or partial Fiscal Years commencing on or after January 1, 2021, less prior losses of the Company allocated to such Member (or its predecessor) for full or partial Fiscal Years commencing on or after January 1, 2021, in each case, as determined by the Manager and to the extent such prior losses are available to reduce such income over (ii) the cumulative Tax Distributions made to such Member after the closing date of the IPO pursuant to Sections 4.01(b)(i), 4.01(b)(ii) and 4.01(b)(iii) and, if applicable with respect to such Fiscal Year, pursuant to Section 4.1(a) of the Previous LLC Agreement; provided that, in the case of the Corporation, such Assumed Tax Liability (x) shall be computed without regard to any increases to the tax basis of the Company’s property pursuant to Sections 734(b) or 743(b) of the Code and (y) to the extent permitted under the Credit Agreements and applicable Law, shall in no event be less than an amount that will enable the Corporation to meet both its tax obligations and its obligations pursuant to the Tax Receivable Agreement for the relevant Taxable Year; provided further that, in the case of each Member, and for the avoidance of doubt, such Assumed Tax Liability shall take into account any Code Section 704(c) allocations (including “reverse” 704(c) allocations) to the Member.

  • Transaction Tax Deductions means any Tax deductions relating to (i) any pay down or satisfaction of Company Indebtedness or other Indebtedness, (ii) the payment or incurrence of any Transaction Expenses or Transaction Bonus Payments and (iii) any other deductible payments attributable to the Contemplated Transactions economically borne by the Seller. For this purpose, any success-based fees shall be treated as deductible in accordance with Rev. Proc. 2011-29.

  • Income Tax Act means the Income Tax Act, 1962 (Act No. 58 of 1962);

  • U.S. Tax Code means the United States Internal Revenue Code of 1986, as amended; and

  • Pre-Closing Tax Returns has the meaning specified in Section 8.04(a).

  • non-taxable territory means the territory which is outside the taxable territory;

  • Transaction Payroll Taxes means the employer portion of any employment or payroll Taxes with respect to any bonuses, severance, option cashouts, Change in Control Payments or other compensatory payments in connection with the transactions contemplated by this Agreement, whether payable by Buyer, the Company or its Subsidiaries.

  • Tax Law means the law of any governmental entity or political subdivision thereof relating to any Tax.

  • Foreign taxes means value-added taxes and custom duties assessed by a foreign government on a commodity. It does not include foreign sales taxes.

  • Income Tax Expense means for Borrower and its Subsidiaries, on a consolidated basis for any period, all state and federal franchise or income taxes paid or due to be paid during such period.

  • Pre-Closing Tax Return has the meaning set forth in Section 7.1(a).

  • Pre-Tax Contributions means, for any Participant, the aggregate of the Participant's Basic Pre-Tax Contributions and Supplemental Pre-Tax Contributions contributed to the applicable Pre-Tax Contribution Account.

  • Change in Tax Law means the enactment, promulgation, execution or ratification of, or any change in or amendment to, any law (or in the application or official interpretation of any law) that occurs on or after the date on which the relevant Transaction is entered into.

  • U.S. Tax Person A citizen or resident of the United States, a corporation, partnership (except to the extent provided in applicable Treasury regulations) or other entity created or organized in or under the laws of the United States, any State thereof or the District of Columbia, an estate whose income is subject to United States federal income tax regardless of its source, or a trust if a court within the United States is able to exercise primary supervision over the administration of such trust, and one or more such U.S. Tax Persons have the authority to control all substantial decisions of such trust (or, to the extent provided in applicable Treasury regulations, certain trusts in existence as of August 20, 1996 that have elected to be treated as U.S. Tax Persons).

  • Actual Tax Liability means, with respect to any Taxable Year, the liability for Covered Taxes of the Corporation (a) appearing on Tax Returns of the Corporation for such Taxable Year and (b) if applicable, determined in accordance with a Determination (including interest imposed in respect thereof under applicable law).