Direct Tax Owner definition

Direct Tax Owner means a beneficial owner of Class E Notes, Subordinated Notes or Membership Interests that (x) is not and will not be treated as a Flowthrough Entity or (y) less than 40% of the assets of which are represented, directly or indirectly, by the Notes and Membership Interests at the time it becomes a Flowthrough Entity.
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Direct Tax Owner. With respect toA beneficial owner of Subordinated Notes or Potential Equity Notes (or any Class of Secured Debt recharacterized as equity for U.S. federal income tax purposes) that (x) is not and will not be treated as a partnership, grantor trust or S corporation for U.S. federal income tax purposes or (y) is a partnership, grantor trust or S corporation for U.S. federal income tax purposes and less than 40% of the assets of which are and will be represented, directly or indirectly, by the Subordinated Notes and the Potential Equity Notes, the meaning specified in Section 2.12(i (and any other equity interests in the Issuer).
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Direct Tax Owner. The meaning specified in Section 4.02(k).
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More Definitions of Direct Tax Owner

Direct Tax Owner. With respect to the Subordinated Notes and Potential Equity Notes, the meaning specified in Section 2.12(i).
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Direct Tax Owner. With respect to the Class A-1R Notes, the meaning specified in Section 2.5(q) and with respect to the Subordinated Notes, the meaning specified in Section 2.5(p).
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Direct Tax Owner. The meaning specified in Section 4.02(k). "Downgrade Draw": The meaning specified in Section 3.08(c).
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Related to Direct Tax Owner

  • Indirect Tax means any goods and services tax, consumption tax, value added tax or any tax of a similar nature.

  • Indirect Taxes means value added taxes, sales taxes, consumption taxes and other similar taxes.

  • Transfer Tax means all transfer, documentary, sales, use, stamp, registration, value added and other such Taxes and fees (including any penalties and interest) incurred in connection with the transactions contemplated under this Agreement.

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

  • 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.

  • Gross receipts tax means any gross receipts, sales, use, excise, value added or any similar tax.

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

  • Relevant Taxing Jurisdiction shall have the meaning specified in Section 4.07(a).

  • 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).

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

  • Hypothetical Tax Liability means, with respect to any Taxable Year, the Hypothetical Federal Tax Liability for such Taxable Year, plus the Hypothetical Other Tax Liability for such Taxable Year.

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

  • taxable territory means the territory to which the provisions of this Act apply;

  • Connection Income Taxes means Other Connection Taxes that are imposed on or measured by net income (however denominated) or that are franchise Taxes or branch profits Taxes.

  • Special Taxes means any and all present or future taxes, levies, imposts, deductions, charges or withholdings, or any liabilities with respect thereto, including those arising after the date hereof as result of the adoption of or any change in law, treaty, rule, regulation, guideline or determination of a Governmental Authority or any change in the interpretation or application thereof by a Governmental Authority but excluding, in the case of Lender, such taxes (including income taxes, franchise taxes and branch profit taxes) as are imposed on or measured by Lender’s net income by the United States of America or any Governmental Authority of the jurisdiction under the laws under which Lender is organized or maintains a lending office.

  • 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.

  • Assigned Annual Special Tax means the Special Tax of that name described in Section D.

  • Relevant Tax Jurisdiction ’ shall mean, in the case of payment by the Issuer, the Grand-Duchy of Luxembourg (where the Issuer is FFT), Canada (where the Issuer is FFC) or the United States of America (where the Issuer is FFNA) or any political subdivision or any authority thereof or therein having power to tax and, in the case of payment by the Guarantor, shall mean the Republic of Italy and any political subdivision or any authority thereof or therein having power to 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;

  • Distribution Taxes means any Taxes incurred solely as a result of the failure of the Intended Tax Treatment of the Restructuring, the Contribution or the Distribution.

  • Local taxes means all taxes levied other than taxes levied for school operating purposes.

  • State premium tax liability means any liability

  • 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.

  • Annual Special Tax means the Special Tax actually levied in any Fiscal Year on any Assessor’s Parcel.

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

  • 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).