Hypothetical Tax Amount definition

Hypothetical Tax Amount means, with respect to each Member, an amount equal to the product of (i) the combined maximum marginal prevailing federal and highest state and local income tax rates applicable to such Member (taking into account the deductibility of state and local taxes and the character of income and loss allocated as it effects the applicable tax rate for a taxable year), and (ii) the net amount of cumulative Net Profits and other items of tax gain and income, net of Net Losses and other items of tax loss and deduction, allocated to such Member (or such Member’s predecessor in interest) for tax purposes since inception of the Company through the end of the applicable Fiscal Year (excluding all allocations under Section 704(c) of the Code). If the Hypothetical Tax Amount for a Member as of the end of a taxable year is negative, such amount shall be treated as being zero.
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Hypothetical Tax Amount means, with respect to each Member and each Quarter, an amount equal to the product of (a) the maximum prevailing federal and highest state and local income tax rates applicable to the Initial Class C Member (including the effect of the tax on Net Investment Income as defined in Section 1411 of the Code, and taking into account the deductibility of state and local taxes for federal income tax purposes and the character of income and loss allocated as it affects the applicable tax rate), and (b) the net amount of cumulative income and gain, less losses, deductions and credits, allocated or estimated by the Company to be allocable to such Member (or the Member’s predecessor in interest) for federal income tax purposes in the applicable allocation year, but specifically excluding (i) allocations under Section 704(c) of the Code or the Treasury Regulations thereunder in respect of any Adjustment Event occurring prior to the date of this Agreement or in connection with the admission of the Class C Member or Class D Member pursuant to this Agreement and (ii) the amount of income or gain recognizable by the Class D Member resulting from the transactions contemplated by the Holdings LP Contribution Agreement.
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Hypothetical Tax Amount means, with respect to each Member, an amount equal to the product of (a) the amount of such Member’s Allocated Income, multiplied by (b) the Tax Rate. The Management Committee shall use the information reasonably available to it at the time in calculating the Hypothetical Tax Amount for each Member. Any distributions to a Member under this Section 5.08 shall be treated as a preliminary distribution of future amounts due to such Member under Section 5.01 and any future distributions due to such Member under Section 5.01, including distributions in liquidation pursuant to Section 12.02, shall be adjusted so that aggregate distributions are according to Section 5.01 priorities. In the event that, at the time of liquidation of the Company distributions under this Section 5.08 have not been fully recouped against amounts distributable under Section 5.01 and Section 12.02, the Member who received such excess distributions shall be obligated to recontribute the amount of such excess to the Company in connection with the dissolution of the Company.
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More Definitions of Hypothetical Tax Amount

Hypothetical Tax Amount means, with respect to each Member, an amount equal to the product of (i) the combined maximum prevailing federal and highest state and local income tax rates applicable to any Member (taking into account the deductibility of state and local tax rates and the character of income and loss allocated as it effects the applicable tax rate), and (ii) the net amount of cumulative Profits (net of Losses) allocated to such Member (or the Member’s predecessor in interest) for tax purposes since inception of Company through the end of the applicable Tax Allocation Period.
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Hypothetical Tax Amount means, with respect to each Member and each Quarter, an amount equal to the product of (i) the maximum prevailing federal and highest state and local income tax rates applicable to the Initial Class C Member (including the effect of the tax on Net Investment Income as defined in Section 1411 of the Code, and taking into account the deductibility of state and local taxes for federal income tax purposes and the character of income and loss allocated as it affects the applicable tax rate), and (ii) the net amount of cumulative income and gain, less losses, deductions and credits, allocated or estimated by the Company to be allocable to such Member (or the Member’s predecessor in interest) for federal income tax purposes in the applicable Allocation Year, but specifically excluding allocations under Section 704(c) of the Code or the Treasury regulations thereunder in respect of any Adjustment Event occurring prior to the date of this Agreement or in connection with the admission of the Class C Member pursuant to this Agreement.
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Hypothetical Tax Amount has the meaning specified in Section 6.2.
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Hypothetical Tax Amount means, with respect to each Member for any calendar year, an amount equal to (a) the cumulative amount of U.S. federal, state, and local income taxes that the Board estimates would be due from such Member for such calendar year and all prior calendar years, assuming such Member were an individual subject to federal, state and local income tax at the highest combined marginal tax rate for an individual residing in New York, New York who earned solely the items of income, gain, deduction, loss, and/or credit allocated to or otherwise required to be taken into account by such Member pursuant to Section 3.04 and after taking proper account of loss carryforwards available to individual taxpayers resulting from losses allocated to such Member with respect to its interest in the Company, to the extent not taken into account in prior calendar years, and such other reasonable assumptions as the Board determines, reduced by (b) all distributions previously made to such Member pursuant to Section 3.01(a).
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Hypothetical Tax Amount means with respect to any Member and quarter, an amount equal to the product of (i) the combined maximum prevailing federal and highest state and local income tax rates for such quarter applicable to any Member for individuals (taking into account the deductibility of state and local taxes and the character of income and loss allocated as it effects the applicable tax rate) times (ii) the cumulative sum of income and losses allocated for tax purposes since inception of the Company with respect to the Units of such Member (or his predecessor interest holder) pursuant to this Agreement. Any distribution under this Section 6.2 shall be treated as advances and will be taken into account in determining subsequent distributions under Section 6.1 so that each Member receives the same aggregate distributions it would have received thereunder if this Section 6.2 were not contained in this Agreement.
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Hypothetical Tax Amount has the meaning set forth in Section 5.08. Indebtedness – means any amount (absolute or contingent) payable by the Company as debtor, borrower, issuer, guarantor or otherwise, pursuant to (a) an agreement or instrument involving or evidencing money borrowed, the advance of credit, a conditional sale or a transfer with recourse or with an obligation to repurchase; (b) indebtedness of a third party guaranteed by or secured by (or for which the holder of such indebtedness has an existing right, contingent or otherwise, to be secured by) any lien on assets owned or acquired by the Company, whether or not the indebtedness secured thereby has been assumed; (c) purchase-money indebtedness and capital lease obligations; (d) an interest rate protection agreement, foreign currency exchange agreement or other hedging arrangement; or (e) a letter of credit issued for the account of the Company.
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Related to Hypothetical Tax Amount

  • Hypothetical Tax Liability means, with respect to any Taxable Year, the liability for Taxes of the Corporation (or the Partnerships, but only with respect to Taxes imposed on the Partnerships and allocable to the Corporation) using the same methods, elections, conventions and similar practices used on the relevant Corporation Return but using the Non-Stepped Up Tax Basis instead of the tax basis reflecting the Basis Adjustments of the Adjusted Assets and excluding any deduction attributable to Imputed Interest.

  • Final Tax Amount has the meaning set forth in Section 4.01(b)(ii).

  • Tax Amount has the meaning set forth in Section 4.01(b)(i).

  • Net After Tax Amount means the amount of any Parachute Payments or Capped Payments, as applicable, net of taxes imposed under Code Sections 1, 3101 (b) and 4999 and any State or local income taxes applicable to the Executive on the date of payment. The determination of the Net After Tax Amount shall be made using the highest combined effective rate imposed by the foregoing taxes on income of the same character as the Parachute Payments or Capped Payments, as applicable, in effect on the date of payment.

  • After Tax Amount means the amount of the Aggregate Payments less all federal, state, and local income, excise and employment taxes imposed on the Executive as a result of the Executive’s receipt of the Aggregate Payments. For purposes of determining the After Tax Amount, the Executive shall be deemed to pay federal income taxes at the highest marginal rate of federal income taxation applicable to individuals for the calendar year in which the determination is to be made, and state and local income taxes at the highest marginal rates of individual taxation in each applicable state and locality, net of the maximum reduction in federal income taxes which could be obtained from deduction of such state and local taxes.

  • Pre-Tax Earnings means the Corporation's earnings before income taxes as reported in the Company's Consolidated Income Statement for each fiscal year of the Performance Period, excluding any non-cash charge incurred in accordance with accounting principles generally accepted in the United States of America (GAAP) for any restricted stock or restricted stock unit awards granted during the Performance Period and all options, restricted stock and other equity compensation granted to Directors during the Performance Period.

  • maximum council tax reduction amount means the amount determined in accordance with paragraph 29;

  • Net Tax Benefit has the meaning set forth in Section 3.1(b) of this Agreement.

  • Marginal Tax Rate means the maximum marginal regular Federal individual income tax rate applicable to ordinary income or the maximum marginal regular Federal corporate income tax rate, whichever is greater.

  • Tax Distribution Amount means, with respect to a Member’s Units, whichever of the following applies with respect to the applicable Tax Distribution, in each case in amount not less than zero:

  • 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.

  • Pre-Tax Contributions means, for any Participant, the aggregate of the Participant's Basic Pre-Tax Contributions and Supplemental Pre-Tax Contributions contributed to the applicable Pre-Tax Contribution Account.

  • Net After-Tax Benefit means the Present Value of a Payment net of all federal state and local income, employment and excise taxes imposed on Executive with respect thereto, determined by applying the highest marginal rate(s) applicable to an individual for Executive’s taxable year in which the Change in Control occurs.

  • REMIC 2 Interest Loss Allocation Amount With respect to any Distribution Date, an amount equal to (a) the product of (i) the aggregate Stated Principal Balance of the Mortgage Loans and related REO Properties then outstanding and (ii) the Uncertificated REMIC 2 Pass-Through Rate for REMIC 2 Regular Interest LTAA minus the Marker Rate, divided by (b) 12.

  • After-Tax Account means a Participant’s account to which are credited After-Tax Contributions, if any, and earnings and losses thereon.

  • True-Up Amount means the difference between the ABO calculated by using the member’s actual creditable service and the actual final average compensation as of the member’s effective date in the FRS Investment Plan and the ABO initially transferred.

  • Available Tax Increment means the Gross Tax Increment received by the City from Hennepin County during the period preceding each semi-annual Payment Date, less (i) the amount of tax increment, if any, which the City must pay to the school district, the county and the state pursuant to Minnesota Statutes, Sections 469.177, Subds. 9 and 11; 469.176, Subd. 4h; and 469.175, Subd. 1a, as the same may be amended from time to time, (ii) actual administrative costs of the City in an amount not to exceed 10% of Gross Tax Increment.

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

  • Total Distribution Amount With respect to any Distribution Date, the sum of (i) the aggregate of the Interest Remittance Amounts for such date; (ii) the aggregate of the Principal Remittance Amounts for such date; and (iii) all Prepayment Premiums collected during the related Prepayment Period.

  • Cumulative Net Realized Tax Benefit for a Taxable Year means the cumulative amount of Realized Tax Benefits for all Taxable Years of the Corporate Taxpayer, up to and including such Taxable Year, net of the cumulative amount of Realized Tax Detriments for the same period. The Realized Tax Benefit and Realized Tax Detriment for each Taxable Year shall be determined based on the most recent Tax Benefit Schedule or Amended Schedule, if any, in existence at the time of such determination.

  • Class B Fixed Allocation means, with respect to any Monthly Period following the Revolving Period, the percentage equivalent (which percentage shall never exceed 100%) of a fraction, the numerator of which is the Class B Investor Interest as of the close of business on the last day of the Revolving Period and the denominator of which is equal to the Investor Interest as of the close of business on the last day of the Revolving Period.

  • Post-Distribution Tax Period means a Tax period beginning and ending after the Distribution Date.

  • Pre-Distribution Tax Period means any taxable period (or portion thereof) that ends on or before the Distribution Date.

  • REMIC II Interest Loss Allocation Amount With respect to any Distribution Date, an amount equal to (a) the product of (i) 50% of the aggregate Stated Principal Balance of the Mortgage Loans and REO Properties then outstanding and (ii) the REMIC II Remittance Rate for REMIC II Regular Interest AA minus the Marker Rate, divided by (b) 12.

  • 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).

  • REMIC I Interest Loss Allocation Amount With respect to any Distribution Date, an amount equal to (a) the product of (i) the aggregate Stated Principal Balance of the Mortgage Loans and REO Properties then outstanding and (ii) the REMIC I Remittance Rate for REMIC I Regular Interest I-LTAA minus the Marker Rate, divided by (b) 12.