Contribution Tax Treatment definition

Contribution Tax Treatment shall have the meaning set forth in the recitals.
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Examples of Contribution Tax Treatment in a sentence

  • Unless and until there has been a Final Determination to the contrary, each Party agrees not to take any position on any Tax Return, in connection with any Tax Contest or otherwise that is inconsistent with (a) the allocation of Taxes between LRAD and Parametric Sound as set forth in this Agreement or (b) the Contribution Tax Treatment and the Distribution Tax Treatment.

  • Notwithstanding anything else to the contrary contained in this Agreement or any other agreement, MPI (on behalf of itself and all other members of the MPI Group) hereby confirms and agrees that neither MPI nor any member of the MPI Group will take or permit to be taken any action at any time that could jeopardize the Contribution Tax Treatment, the Distribution Tax Treatment or both.

  • Notwithstanding anything else to the contrary contained herein, in the case of any such Tax Contest relating to the Contribution Tax Treatment, absent a settlement of such Tax Contest pursuant to the preceding sentence, Bentley shall be required to exhaust, at CPEX’s expense, all administrative remedies available with respect to such Tax Contest.

  • Unless and until there has been a Final Determination to the contrary, each Party agrees not to take any position on any Tax Return, in connection with any Tax Contest or otherwise that is inconsistent with (a) the allocation of Taxes between the Myriad Group and the MPI Group as set forth in this Agreement or (b) the Contribution Tax Treatment and the Distribution Tax Treatment.

  • Subject to Bentley’s control right, upon request by CPEX, CPEX shall, at CPEX’s expense, be allowed to participate in the handling of any such Tax Contest with respect to any item that may affect the liability of CPEX or any member of the CPEX Group under this Agreement or that relates to the Contribution Tax Treatment, and Bentley shall not settle any such Tax Contest without the consent of CPEX, which consent shall not be unreasonably withheld, conditioned or delayed.

  • Notwithstanding anything else to the contrary contained in this Agreement or any other agreement, LRAD hereby confirms and agrees that LRAD will not take or permit to be taken any action at any time that could jeopardize the Contribution Tax Treatment, the Distribution Tax Treatment or both.

  • Notwithstanding anything else to the contrary contained herein, in the case of any such Tax Contest relating to the Contribution Tax Treatment or the Distribution Tax Treatment, absent a settlement of such Tax Contest pursuant to the preceding sentence, LRAD shall be required to exhaust, at Parametric Sound’s expense, all administrative remedies available with respect to such Tax Contest.

  • Unless and until there has been a Final Determination to the contrary, each Party agrees not to take any position on any Tax Return, in connection with any Tax Contest or otherwise that is inconsistent with (a) the allocation of Taxes between the Bentley Group and the CPEX Group as set forth in this Agreement or (b) the Contribution Tax Treatment and the Distribution Tax Treatment.

  • Notwithstanding anything else to the contrary contained in this Agreement or any other agreement, Bentley (on behalf of itself and all other members of the Bentley Group) hereby confirms and agrees that neither Bentley nor any member of the Bentley Group will take or permit to be taken any action at any time that could jeopardize, the Contribution Tax Treatment, the Distribution Tax Treatment or both.

  • Notwithstanding anything else to the contrary contained in this Agreement or any other agreement, CPEX (on behalf of itself and all other members of the CPEX Group) hereby confirms and agrees that neither CPEX nor any member of the CPEX Group will take or permit to be taken any action at any time that could jeopardize the Contribution Tax Treatment, the Distribution Tax Treatment or both.

Related to Contribution Tax Treatment

  • Tax Treatment [One or more elections will be made to treat the assets of the Trust Fund as a REMIC.] [The Trust Fund will be treated as a "grantor trust" for federal income tax purposes.]

  • Intended Tax Treatment has the meaning set forth in the Recitals.

  • Distribution Taxes means any Taxes incurred solely as a result of the failure of any of the Transactions to qualify for the Intended Tax Treatment of such Transaction.

  • Pre-Distribution Tax Period means any taxable period (or portion thereof) that ends on or before the Distribution Date.

  • 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.

  • Post-Distribution Tax Period means a Tax year beginning and ending after the Distribution Date.

  • Income Tax Return means any Tax Return relating to Income Taxes.

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

  • Transaction Tax Deductions means any Tax deductions, whether accruing before, on or after the Closing Date, relating to (a) any pay down or satisfaction of Indebtedness in connection with the Merger, (b) the payment or incurrence of any Transaction Expenses, and (c) any other deductible payments attributable to the Merger and economically borne by Sellers. For this purpose, any success-based fees shall be treated as deductible in accordance with the seventy percent safe-harbor election in Rev. Proc. 2011-29.

  • After-Tax Contributions means amounts withheld from an Employee’s Compensation pursuant to a Salary Reduction Agreement after all applicable state and federal taxes have been deducted. Such amounts are withheld for purposes of purchasing one or more of the Benefit Package Options available under the Plan.

  • 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.

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

  • Prohibited Transaction Tax Any tax imposed under Section 860F of the Code. Prospectus: The prospectus dated July 19, 2004 as supplemented by the prospectus supplement dated July 26, 2004, relating to the Class A, Class B-1, Class B-2 and Class B-3 Certificates.

  • Income Tax Returns means all Tax Returns relating to Income Taxes.

  • Precontribution Gain has the meaning set forth in subparagraph 4(c) of Exhibit B.

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

  • Transaction Taxes has the meaning set forth in Section 2.6.

  • Change in Tax Classification has the meaning set forth in Section 5.2(h).

  • Tax Asset means any net operating loss, net capital loss, investment tax credit, foreign tax credit, charitable deduction or any other credit or tax attribute that could be carried forward or back to reduce Taxes (including deductions and credits related to alternative minimum Taxes).

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

  • Taxable Allocation means, with respect to any Series, the allocation of any net capital gains or other income taxable for federal income tax purposes to a dividend paid in respect of such Series.

  • Net Tax Benefit has the meaning set forth in Section 3.1(b) of this Agreement.

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

  • Income Tax means any federal, state, local or foreign Tax (a) based upon, measured by or calculated with respect to net income, profits or receipts (including, without limitation, capital gains Taxes and minimum Taxes) or (b) based upon, measured by or calculated with respect to multiple bases (including, without limitation, corporate franchise taxes) if one or more of the bases on which such Tax may be based, measured by or calculated with respect to, is described in clause (a), in each case together with any interest, penalties, or additions to such Tax.

  • Tax means any present or future tax, levy, impost, duty, charge, assessment or fee of any nature (including interest, penalties and additions thereto) that is imposed by any government or other taxing authority in respect of any payment under this Agreement other than a stamp, registration, documentation or similar tax.

  • Pre-Tax Income means income, as determined by GAAP, prior to deduction of the Bonus Pool (as hereinafter defined) and income taxes, and if applicable, after the deduction of any bonus pool of a future officer bonus plan adopted by the Company relating to an applicable Award Year and adjustments approved by the Board as described herein.