Federal Income Tax Matters definition

Federal Income Tax Matters and “Description of Shares” in the Prospectus, insofar as such statements constitute statements of law (except that with regard to the statements set forth under the heading “Certain Federal Income Tax Matters” and “Federal Income Tax Matters,” only to the extent that such statements constitute statements of Federal income tax law), descriptions of statutes, rules or regulations, or summaries of the legal matters or proposed legislation referred to therein, have been reviewed by such counsel and are correct in all material respects and provide a fair summary of such matters;
Sample 1

Examples of Federal Income Tax Matters in a sentence

  • Federal Income Tax Matters 5 ARTICLE THREE CERTIFICATES AND TRANSFER OF INTERESTS Section 3.01.

  • See Section 6 ("Certain Federal Income Tax Matters") and the Instructions to the Assignment of Partnership Interest.

  • This is largely due to the unpredictable nature of PFIC income that RAP is required to recognize on a mark-to-market (or deemed) basis each year under the U.S. federal income tax rules with respect to PFICs. See "U.S. Federal Income Tax Matters: Tax Consequences of Certain Investments" in the SAI.

  • The statements made in the Registration Statement under the heading "Federal Income Tax Matters" are correct.

  • We consent to the reference to our firm under the caption "Certain Federal Income Tax Matters" in the Proxy Statement included in the Registration Statement and to the filing of this opinion as an exhibit to the Proxy Statement and to the Registration Statement.

  • We hereby consent to the filing of this opinion as an exhibit to the Registration Statement and to the references to this firm under the captions "Federal Income Tax Consequences" and "Validity of Shares and Federal Income Tax Matters" in the Proxy Statement/Prospectus forming a part of the Registration Statement as having passed upon certain tax aspects of the Merger on behalf of Southdown.

  • This opinion is subject to the explanations and qualifications set forth under the caption "United States Federal Income Tax Matters" in the Prospectus.

  • Additionally, our advice has formed the basis for the description of the selected federal income tax consequences of the purchase, ownership and disposition of the Notes to an original purchaser who is subject to United States federal income tax that appears under the heading "United States Federal Income Tax Matters" in the Prospectus (the "Tax Description").

  • We have reviewed the discussion entitled "Certain Federal Income Tax Matters" contained in the Registration Statement and believe that, insofar as it relates to statements of law and legal conclusions, is correct in all material respects.

  • If we are required to indemnify Entergy and its subsidiaries and their respective officers and directors under the circumstances set forth in the Federal Income Tax Matters Agreement, we may be subject to substantial liabilities.

Related to Federal Income Tax Matters

  • Federal Income Tax means any Tax imposed by Subtitle A of the Code, and any interest, penalties, additions to tax, or additional amounts in respect of the foregoing.

  • Consolidated federal income tax return means a consolidated return filed for federal income tax purposes pursuant to section 1501 of the Internal Revenue Code.

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

  • Income Tax Act means the Income Tax Act (Canada), as amended from time to time;

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

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

  • Income Tax means any federal, state, local, or foreign income tax, including any interest, penalty, or addition thereto, whether disputed or not.

  • Foreign Income Tax means any Tax imposed by any foreign country or any possession of the United States, or by any political subdivision of any foreign country or United States possession, which is an income tax as defined in Treasury Regulation Section 1.901-2, and any interest, penalties, additions to tax, or additional amounts in respect of the foregoing.

  • IRS means the United States Internal Revenue Service.

  • Internal Revenue Service means the United States Internal Revenue Service.

  • 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).

  • Federal Tax Certificate means the Issuer's Federal Tax Certificate dated as of the Issue Date, as the same may be amended or supplemented in accordance with the provisions thereof.

  • Taxable Event means any change in control or other event which triggers the imposition of any Excise Tax on any Payment.

  • State Income Tax means any Tax imposed by any State of the United States (or by any political subdivision of any such State) or the District of Columbia, or any city or municipality located therein, which is imposed on or measured by net income, including state and local franchise or similar Taxes measured by net income, and any interest, penalties, additions to tax, or additional amounts in respect of the foregoing.

  • PAYEE TAX REPRESENTATIONS Each representation specified in the Schedule as being made by it for the purpose of this Section 3(f) is accurate and true.

  • 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.

  • Tax Matters means all tax matters including criminal tax matters,

  • Income Taxes means any Tax which is based upon, measured by, or calculated with respect to (i) net income or profits (including, but not limited to, any capital gains, gross receipts, value added or minimum Tax) or (ii) multiple bases (including, but not limited to, corporate franchise, doing business or occupation Taxes) if one or more of the bases upon which such Tax may be based, by which it may be measured, or with respect to which it may be calculated is described in clause (i) of this sentence.

  • Tax Matter has the meaning set forth in Section 7.01.

  • Excise Tax Act means the Excise Tax Act (Canada);