Examples of Corporate Holdcos in a sentence
The Realized Tax Benefit or Realized Tax Detriment for each Taxable Year is intended to measure the decrease or increase in the actual liability for Taxes of the Corporate Holdcos for such Taxable Year attributable to the Basis Adjustments and Imputed Interest, determined using a “with and without” methodology.
Within five (5) calendar days of a Tax Benefit Schedule delivered to an applicable Limited Partner becoming final in accordance with Section 2.04(a), each of the Corporate Holdcos shall pay to the applicable Limited Partner for such Taxable Year the portion of the Tax Benefit Payment determined pursuant to Section 3.01(b) that is allocable to such Limited Partner.
Each of the Corporate Holdcos and each applicable Limited Partner shall bear their own costs and expenses of such proceeding, unless the Limited Partner has a prevailing position that is more than 10% of the payment at issue, in which case the Corporate Holdco shall reimburse such Limited Partner for any reasonable out-of-pocket costs and expenses in such proceeding.
Each such payment shall be made by wire transfer of immediately available funds to a bank account of the applicable Limited Partner previously designated by such Limited Partner to each of the Corporate Holdcos or as otherwise agreed by the Corporate Holdco and the applicable Limited Partner.
Currently, Burcon has over 300 additional patent applications that are being reviewed by the respective patent offices in various countries.RESULTS OF OPERATIONS As at December 31, 2017, Burcon has not yet generated any significant revenues from its technology.
Except as otherwise provided herein, each of the Corporate Holdcos and the Group Partnerships shall have full responsibility for, and sole discretion over, all Tax matters concerning each of the Corporate Holdcos and the Group Partnerships, respectively, including without limitation the preparation, filing or amending of any Tax Return and defending, contesting or settling any issue pertaining to Taxes.
Each of the Corporate Holdcos and the applicable Limited Partner Representative(s) shall bear its own costs and expenses of such proceeding, unless any applicable Limited Partner Representative has a prevailing position that is more than 10% of the payment at issue, in which case the applicable Corporate Holdco shall reimburse such Limited Partner Representative for any reasonable out-of-pocket costs and expenses in such proceeding.
For the avoidance of doubt, the actual liability for Taxes will take into account the deduction of the portion of the Tax Benefit Payment that must be accounted for as interest under the Code based upon the characterization of Tax Benefit Payments as additional consideration payable by the Corporate Holdcos for the Group Partnership Units acquired in an Exchange.
Notwithstanding the foregoing, Section 3.03 shall not apply to any payment made by the Corporate Holdcos pursuant to Section 4.03.
The Corporate Holdcos shall engage a nationally recognized accounting or law firm to review each Tax Benefit Schedule prior to delivery.