Federal Income Tax Treatment definition

Federal Income Tax Treatment is amended by adding at the end thereof the following new paragraph: Notwithstanding anything herein to the contrary, if the Employer reasonably anticipates that if a distribution were made as scheduled under the Agreement it would result in a loss of the Employer’s tax deduction due to the application of Section 162(m) of the Internal Revenue Code, such distribution may be delayed and paid during the Employer’s first taxable year in which the Employer reasonably anticipates that the Employer’s tax deduction will not be limited or eliminated by the application of Section 162(m) of the Internal Revenue Code. Notwithstanding the foregoing, no distribution under the Agreement may be deferred in accordance with this paragraph unless all scheduled distributions to the Employee and all similarly situated individuals that could be delayed in accordance with Treas. Reg. Section 1.409A-2(b)(7)(i) are also delayed. RESOLVED FURTHER that the amendments to the Bonus Agreement set forth above shall be effective immediately upon the closing of the proposed private common stock offering (the “Private Offering”) by the Company’s ultimate parent entity, State National Companies, Inc., a Delaware corporation (“SNCI”), provided (1) that such closing occurs prior to July 30, 2014 and (2) the purchase price per share of common stock sold to investors in the Private Offering implies an enterprise value for SNCI immediately prior to such closing of at least $300 million. If the Private Offering is not completed upon these terms, this Amendment shall be void ab initio and of no further force or effect and the Bonus Agreement shall remain in effect unchanged.
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Examples of Federal Income Tax Treatment in a sentence

  • Aprill, The Integral, the Essential, and the Instrumental: Federal Income Tax Treatment of Governmental Affiliates, 23 I.

  • Federal Income Tax Treatment of the Issuing Entity 9 Section 2.12.

  • See the section entitled "Taxation—United States Federal Income Taxation—Taxation of Securities issued by JPMCFC, JPMorgan Chase & Co. or JPMorgan Chase Bank, N.A.—Taxation of U.S. Holders—U.S. Federal Income Tax Treatment of Securities Treated as other than Debt— Specific Considerations for U.S. Holders of LEPWs" below.

  • Investors should consult their own tax advisors in determining the tax consequences to them of holding Notes, including the application to their particular situation of the U.S. federal income tax considerations discussed herein, as well as the application of applicable tax laws.U.S. Federal Income Tax Treatment of Credit Default Swaps Under current U.S. federal income tax law, the treatment of credit default swaps is unclear.

  • Federal Income Tax Treatment of the Issuing Entity 8 Section 2.12.

  • Aprill, The Integral, the Essential, and the Instrumental: Federal Income Tax Treatment of Governmental Affiliates, 23 J.

  • See the section entitled "Taxation—United States Federal Income Taxation—Taxation of Securities issued by JPMorgan Chase & Co. or JPMorgan Chase Bank, N.A.—Taxation of U.S. Holders—U.S. Federal Income Tax Treatment of Securities Treated as other than Debt—Specific Considerations for U.S. Holders of LEPWs" below.

  • Future payments with respect to the EON will be subject to the OID rules if such security constitutes indebtedness for Federal income tax purposes (see "Federal Income Tax Treatment Of Payments On The Litigation Trust Certificates—The EON-OID," below).

  • While the exchange and cancellation of your incentive stock options will not give rise to any tax consequences, you should refer to the tax discussion below regarding "Federal Income Tax Treatment of Nonstatutory Stock Options," because your New Options will not be incentive stock options and may be subject to different tax treatment than your Eligible Options.

  • None Federal Income Tax Treatment of Distributions Total distribution (contribution + earnings) taxable as income in year withdrawn except for any prior non- deductible contributions Tax-free if a qualified distribution For certain tax payers, the Traditional IRA may be more attractive than a Xxxx XXX.

Related to Federal Income Tax Treatment

  • 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.

  • Tax Treatment [One or more elections will be made to treat the assets of the Trust Fund as a REMIC.] [The Trust Fund will be treated as a "grantor trust" for federal income tax purposes.]

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

  • Intended Tax Treatment has the meaning set forth in the Recitals.

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

  • Federal internal revenue code means the internal revenue code of the United States in effect on the last day of the taxpayer's tax year.

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

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

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

  • 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.

  • U.S. Tax Code means the United States Internal Revenue Code of 1986, as amended.

  • 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).

  • IRS means the United States Internal Revenue Service.

  • 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.

  • the Code means the Pension Regulator’s Code of Practice No 14 governance and administration of public service pension schemes.

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

  • tax treaty means an agreement for the avoidance of double taxation entered into between South Africa and another country;

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

  • Internal Revenue Code means the Internal Revenue Code of 1986, as amended, or any successor statute.

  • Treatment means any method, technique, or process, including neutralization, designed to change the physical, chemical, or biological character or composition of any hazardous waste so as to neutralize such waste, or so as to recover energy or material resources from the waste, or so as to render such waste non-hazardous, or less hazardous; safer to transport, store, or dispose of; or amenable for recovery, amenable for storage, or reduced in volume.

  • 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.

  • U.S. Internal Revenue Code means the United States Internal Revenue Code of 1986, as amended.

  • foreign tax means any Foreign Income Taxes or Foreign Other Taxes.

  • Code Section 409A means Section 409A of the Code and all regulations issued thereunder and applicable guidance thereto.