Forfeiture Allocations definition

Forfeiture Allocations has the meaning set forth in Section 4.2.
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Forfeiture Allocations has the meaning set forth in Section 6.02(e).
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Forfeiture Allocations has the meaning set forth in Section 6.4(f). “Fresh Benefit” has the meaning set forth in Section 9.4.
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Examples of Forfeiture Allocations in a sentence

  • For the avoidance of doubt, the Company is entitled to make Forfeiture Allocations and, once required by applicable final or temporary guidance, allocations of Net Income and Net Loss will be made in accordance with Proposed Treasury Regulations Section 1.704-1(b)(4)(xii)(c) or any successor provision or guidance.

  • ACI: American Concrete Institute.GC: General Conditions of Construction Contracts of the City and County of Honolulu.

  • Thus, if the partnership in the above example had no gain or loss in 2006, but had either gains or losses in 2007, we think it would be appropriate to permit the Forfeiture Allocations in 2007 so long as A continued to be a partner of the partnership during that year.7) Amount of Required Forfeiture Allocation upon Partial Forfeiture.

  • The grant recipient must disclose to MOSTI in writing, of the existence of the Project Intellectual Property not later than 60 days from the Project Completion Date.

  • We recommend that the final regulations provide guidance as to how the amount of required Forfeiture Allocations should be determined in cases where a partner forfeits part (but not all) of his partnership interest.

  • The Company and the Members acknowledge that allocations like those described in Proposed Treasury Regulations Section 1.704-1(b)(4)(xii)(c) (" Forfeiture Allocations") result from the allocations of Net Income and Net Loss provided for in this Agreement.

  • Similarly, in addition to allowing a partnership to create notional items to make any necessary Forfeiture Allocations, we believe that the Forfeiture Allocations should be permitted in subsequent years to the extent that there were insufficient available items in the year of forfeiture.

  • We note that, in the analogous Subchapter S area, a service provider who makes a Section 83(b) election with respect to unvested stock in an “S” corporation is treated as an owner of the stock for tax purposes and no Forfeiture Allocations are required if such unvested shares are subsequently forfeited.

  • Nevertheless, we believe that partnerships should have some flexibility to adjust the makeup of the Forfeiture Allocations in cases where the adjustments are reasonably designed to allow the character of the forfeiting allocation to match the character of the allocations giving rise to the Forfeiture Allocation.

  • This assumption can prove incorrect and in these cases the Forfeiture Allocations will further distort the relative tax positions of the existing partners.Example 15: A acquires an unvested profits interest for services on January 1, 2005 and makes a timely election under Section 83(b) for the interest.


More Definitions of Forfeiture Allocations

Forfeiture Allocations has the meaning set forth in Section VI.2(e).
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Forfeiture Allocations mean allocations, to a Restricted Unit Member who has made a Section 83(b) election with respect to the Member's Interest, of gross income and gain or gross deduction and loss (to the extent such items are available) for the taxable year of the forfeiture of such Interest in a positive or negative amount equal to (1) the excess (not less than zero) of (a) the amount of distributions to the Member with respect to such Member's Membership Interest over (b) the amounts paid for such Membership Interest minus (2) the cumulative net income (or loss) allocated to the Restricted Unit Member with respect to such Member's Membership Interest.
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Related to Forfeiture Allocations

  • Required Allocations means any allocation of an item of income, gain, loss or deduction pursuant to Section 6.1(d)(i), Section 6.1(d)(ii), Section 6.1(d)(iv), Section 6.1(d)(v), Section 6.1(d)(vi), Section 6.1(d)(vii) or Section 6.1(d)(ix).

  • Curative Allocation means any allocation of an item of income, gain, deduction, loss or credit pursuant to the provisions of Section 6.1(d)(ix).

  • Employer Contribution means the amount paid by an employer, as determined by the employer rate, including the normal and deficiency rates, contributions, and funds wherever used in this chapter.

  • Employer Contribution Account means, for any Participant, the account established by the Administrator or Trustee to which Employer Contributions made under Section 3.5 for the Participant's benefit are credited.

  • Capital Account Limitation has the meaning set forth in Section 4.05(b) hereof.