Effectively Realized definition

Effectively Realized and "Effectively Realizes") means, with respect to a tax saving, tax benefit or tax attribute, the earliest to occur of (i) the receipt by a member of the Delta Woodside Tax Group, a member of the Delta Apparel Tax Group or a member of the Duck Head Tax Group of cash from a Taxing Authority reflecting such tax saving, tax benefit or tax attribute, (ii) the application of such tax saving, tax benefit or tax attribute to reduce (A) the Tax liability on a Return of any of such corporations or of any affiliated, consolidated, combined or unitary group of which any of such corporations is a member, or (B) any other outstanding Tax liability of any of such corporations or of such group, or (iii) a Final Determination of the entitlement of any of such corporations or of such group to such tax saving, tax benefit or tax attribute.
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Effectively Realized and "Effectively Realizes") means, with respect to a tax saving, tax benefit or tax attribute, the earliest to occur of (i) the receipt by any of Holdings, a member of the Nabisco Tax Group or a member of the RJRN Tax Group of cash from a Taxing Authority reflecting such tax saving, tax benefit or tax attribute, (ii) the application of such tax saving, tax benefit or tax attribute to reduce (A) the tax liability on a Return of any of such corporations or of any affiliated, consolidated, combined or unitary group of which any of such corporations is a member, or (B) any other outstanding tax liability of any of such corporations or of such group, or (iii) a Final Determination of the entitlement of any of such corporations or of such group to such tax saving, tax benefit or tax attribute.
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Effectively Realized or “Effectively Realizes”) means, with respect to a Tax Benefit, including from the use of any Tax Attribute, the earliest to occur of (i) the receipt by SnackCo or GroceryCo (or any other member of the SnackCo Post-Distribution Group or any member of the GroceryCo Post-Distribution Group) of cash from a Taxing Authority reflecting such Tax Benefit or (ii) the application of such Tax Benefit to reduce any payments, including estimated Tax payments, with respect to (A) the Tax liability on a Tax Return of any of such entities or of any consolidated group of which any of such entities is a member or (B) any other outstanding Tax liability of any of such entities or of any such consolidated group.
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Examples of Effectively Realized in a sentence

  • Provided, however, the amount SnackCo shall pay to GroceryCo under this Section 4.04(b) related to any adjustment shall not exceed the lesser of (x) the Tax Benefit(s) Effectively Realized (whether Effectively Realized with respect to the same taxable period or one or more other taxable periods) by the member of the SnackCo Post-Distribution Group or (y) the Tax Detriment incurred by the member of the GroceryCo Post-Distribution Group.

  • If a Party (or member of its Group) receives any indemnity or reimbursement payment under this Agreement attributable to a Recoverable Tax that was considered non-recoverable and such Recoverable Tax is later recovered, such Party (or member of its Group) will return the portion of the payment it received attributable to the recovered portion of such Recoverable Tax (determined on a first in, first out basis) to the other Party within thirty days of the date such recovery is Effectively Realized.

  • Provided, however, that the amount GroceryCo shall pay to SnackCo under this Section 4.04(a) related to any adjustment shall not exceed the lesser of (x) the Tax Benefit(s) Effectively Realized (whether Effectively Realized with respect to the same taxable period or one or more other taxable periods) by the member of the GroceryCo Post-Distribution Group or (y) the Tax Detriment incurred by the member of the SnackCo Post-Distribution Group.

  • For purposes of this Section 5.03(a)(ii), the amount of the benefit Effectively Realized is determined under Section 4.02(a)(ii)(D) or Section 4.02(b)(ii) of this Agreement, as the case may be.

  • If a Kraft Pro Forma Return reflects a Tax Asset that may under applicable law be used to reduce a Federal Income Tax or Combined State Tax liability of the Altria Non-Food Group for any taxable period, Altria shall pay to Kraft, or shall reduce the amount owed by Kraft to Altria by, an amount equal to the actual tax saving produced by such Tax Asset within thirty days after such tax saving has been Effectively Realized by the Altria Non-Food Group.

  • If a PMI Pro Forma Return reflects a Tax Asset that may under applicable law be used to reduce a Federal Income Tax or Combined State Tax liability of the Altria U.S. Group for any taxable period, Altria shall pay to PMI, or shall reduce the amount owed by PMI to Altria by, an amount equal to the actual tax saving produced by such Tax Asset within thirty days after such tax saving has been Effectively Realized by the Altria U.S. Group.

  • To the extent PMI has been compensated for any Tax Asset prior to the filing of a final tax return for any year, including with respect to any estimated payments for such year, Altria shall pay to PMI, or PMI shall pay to Altria, as appropriate, the difference between the amount Effectively Realized with respect to each Tax Asset with respect to such interim payments and the amount Effectively Realized with respect to the filing of the final tax return.

  • To the extent Kraft has been compensated for any Tax Asset prior to the filing of a final tax return for any year, including with respect to any estimated payments for such year, Altria shall pay to Kraft, or Kraft shall pay to Altria, as appropriate, the difference between the amount Effectively Realized with respect to each Tax Asset with respect to such interim payments and the amount Effectively Realized with respect to the filing of the final tax return.

  • Aetna agrees to pay to Spinco, within three calendar days of Effective Realization, the actual tax benefit received or otherwise Effectively Realized by the Aetna Consolidated Group from the use in any Pre-Distribution Tax Period of a carryback of any Tax Asset of the Health Group from a Post-Distribution Tax Period.

  • For purposes of this Section 5.03(a)(iii), the amount of a benefit Effectively Realized by a Group equals the difference between (A) the tax liability of the Group taking into account utilization of the Tax Attribute generated by, or allocated to, the other Group and (B) the tax liability of the Group without utilizing the Tax Attribute of the other Group.


More Definitions of Effectively Realized

Effectively Realized and "Effectively Realizes") means, with respect to a Tax Benefit, the first to occur of (i) the receipt by the ▇▇▇▇▇ Group or the Circor Group of cash from a taxing authority reflecting such Tax Benefit or (ii) the application of such Tax Benefit to reduce (A) the tax liability on a Return of the ▇▇▇▇▇ Group or the Circor Group, or (B) any other outstanding tax liability of the ▇▇▇▇▇ Group or the Circor Group.
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Related to Effectively Realized

  • Constructively Own means ownership under the constructive ownership rules described in Exhibit C.

  • Distribution Effective Time has the meaning set forth in the Separation Agreement.

  • Effectively owned or controlled means that a foreign government or any entity controlled by a foreign government has the power, either directly or indirectly, whether exercised or exercisable, to control the election, appointment, or tenure of the Offeror's officers or a majority of the Offeror's board of directors by any means, e.g., ownership, contract, or operation of law (or equivalent power for unincorporated organizations).

  • Defined Benefit Plan Fraction means a fraction, the numerator of which is the projected annual benefit (determined as of the close of the relevant Plan Year) of the Participant under all Defined Benefit Plans maintained by one or more Related Companies, and the denominator of which is the lesser of (i) the product of 1.25 multiplied by the dollar limitation in effect under Section 415(b)(1)(A) of the Code for the Plan Year, or (ii) the product of 1.4 multiplied by the amount which may be taken into account under Section 415(b)(1)(B) of the Code with respect to the Participant for the Plan Year.

  • Constructively Owned shall have the correlative meanings.