Covered Audit Adjustment definition
Covered Audit Adjustment means an adjustment to any partnership-related item (within the meaning of Section 6241(2)(B) of the Code) to the extent such adjustment results in an “imputed underpayment” as described in Section 6225(b) of the Code or any analogous provision of state or local Law.
Covered Audit Adjustment. The meaning specified in Section 7.17(l).
Covered Audit Adjustment has the meaning assigned that term in Section 8.03(d).
Examples of Covered Audit Adjustment in a sentence
Notwithstanding the foregoing, if the Company is required to pay any tax, addition to tax, penalty, or interest following a Push-Out Election because any portion of the applicable Covered Audit Adjustment would otherwise be subject to withholding by the Company under Chapters 3 or 4 of Subtitle A of the Code, any such amounts shall be considered Partnership Level Taxes with respect to the applicable Members.
More Definitions of Covered Audit Adjustment
Covered Audit Adjustment means an adjustment in the amount of any item of income, gain, loss, deduction or credit of the Company, or any Member’s distributive share thereof, to the extent such adjustment results in an Imputed Underpayment.
Covered Audit Adjustment. The meaning specified in Section 7.17(m). “Credit Amendment”: The meaning specified in Section 7.20. “Credit Improved Criteria”: The criteria that will be met if, with respect to any Collateral Obligation, any of the following occur: (a) such Collateral Obligation has experienced a reduction in its credit spread of 10% or more compared to the credit spread in effect as of the Cut-Off Date for such Collateral Obligation, such reduction in spread being determined by reference to an Eligible Loan Index; or (b) such Collateral Obligation has a Market Value above the higher of (i) par and (ii) the initial purchase price paid by the Issuer for such Collateral Obligation. “Credit Improved Obligation”: Any Collateral Obligation, in the Collateral Manager’s reasonable commercial judgment (which judgment shall not be called into question as a result of subsequent events), has significantly improved in credit quality after it was acquired by the Issuer, which may (but need not) be based on one or more of the Credit Improved Criteria; provided that, if a Restricted Trading Period is in effect, (i) such Collateral Obligation satisfies at least one of the Credit Improved Criteria or (ii) the Collateral Manager must obtain the consent of a Majority of the Controlling Class. “Credit Risk Criteria”: The criteria that will be met if, with respect to any Collateral Obligation, any of the following occur: (a) the spread over the Reference Rate or other Eligible Loan Index for such Collateral Obligation has been increased since the date of purchase by the Issuer by (A) 0.25% or more (in the case of a Collateral Obligation with a spread over the applicable reference rate selected by the Collateral Manager in the exercise of its reasonable business judgment (prior to such increase) less than or equal to 2.00%), (B) 0.375% or more (in the
Covered Audit Adjustment has the meaning set forth in Section 9.1(b).
Covered Audit Adjustment. The meaning specified in Section 7.17(j) (Certain Tax Matters).
Covered Audit Adjustment has the meaning set forth in Section 4.05(c)(iii).
Covered Audit Adjustment means an adjustment to any partnership-related item (within the meaning of Section 6241(2)