Hypothetical Tax Basis definition

Hypothetical Tax Basis means, with respect to any asset at any time, the tax basis that such asset would have at such time if no Basis Adjustment had been made as a result of the Redemption or an applicable Taxable Exchange, as the case may be.
Hypothetical Tax Basis means, with respect to any asset at any time, the tax basis that such asset would have at such time if no Basis Adjustment had been made as a result of the Original Sale or an applicable Exchange, as the case may be.
Hypothetical Tax Basis means, with respect to any asset at any time, the tax basis that such asset would have at such time if (i) no Basis Adjustments had been made as a result of the Initial Deemed Exchanges or any applicable Subsequent Deemed Exchanges, as the case may be, or (ii) no Initial ESA Modification Payments had been made, or (iii) no Positive Theatre Access Adjustments or Negative Theatre Access Adjustments had been made, or (iv) no Exchange-Related Payments or ESA-Related Payments had been made.

Examples of Hypothetical Tax Basis in a sentence

  • It is the intention of the parties for Vantiv to pay Fifth Third 85% of the additional Covered Taxes that Vantiv would have been required to pay on Tax Returns that have actually been filed but for (i) the difference between the tax basis in the Original Assets and the Hypothetical Tax Basis and (ii) any deduction attributable to the Imputed Interest, and this Agreement shall be interpreted in accordance with such intention.

  • It is the intention of the parties for Vantiv to pay Advent 85% of the additional Covered Taxes that Vantiv would have been required to pay on Tax Returns that have actually been filed but for the difference between the tax basis in the Original Assets and the Hypothetical Tax Basis, and this Agreement shall be interpreted in accordance with such intention.

  • It is the intention of the parties for Vantiv to pay JPDN 85% of the additional Covered Taxes that Vantiv would have been required to pay on Tax Returns that have actually been filed but for (i) the difference between the tax basis in the Original Assets and the Hypothetical Tax Basis and (ii) any deduction attributable to the Imputed Interest, and this Agreement shall be interpreted in accordance with such intention.


More Definitions of Hypothetical Tax Basis

Hypothetical Tax Basis means, with respect to any asset at any time, the tax basis that such asset would have had at such time if neither any Basis Adjustment nor any Existing Basis Adjustment had been made.
Hypothetical Tax Basis means, with respect to any asset at any time after the Original Sale Date, the tax basis that such asset would have at such time if no Basis Adjustment had been made.
Hypothetical Tax Basis means, with respect to any asset at any time, the tax basis that such asset would have at such time if no Basis Adjustments had been made as a result of the Original Sale or an applicable Taxable Exchange, as the case may be. “Hypothetical Tax Liability” means, with respect to any Covered Taxable Year, the liability for Covered Taxes of HFF using the same methods, elections, conventions and similar practices used on the actual Tax Returns of HFF, but using the Hypothetical Tax Basis instead of the actual tax basis of each relevant asset and excluding any deduction attributable to the Imputed Interest. “Imputed Interest” shall mean any interest imputed under Section 1272, 1274 or 483 or other provision of the Code and any similar provision of applicable U.S. state or local income or franchise Tax law with respect to HFF’s payment obligations under this Agreement. “IRS” means the U.S. Internal Revenue Service. “LIBOR” means, for each month (or portion thereof) during any period, an interest rate per annum equal to the rate per annum reported, on the date two days prior to the first day of such month (or the first preceding LIBOR Business Day if such date is not a LIBOR Business Day) , on the Telerate Page 3750 (or if such screen shall cease to be publicly available, as reported on Reuters Screen page “LIBO” or by any other publicly available source of such market rate) for London interbank offered rates for U.S. dollar deposits for such month (or portion thereof). “LIBOR Business Day” means any day that is a Business Day and on which dealings in deposits in United States dollars are transacted in the London interbank market. “Members” is defined in the recitals. “Opcos” is defined in the recitals. “Original Assets” is defined in the recitals. “Original Sale” is defined in the recitals. “Original Sale Basis Schedule” is defined in Section 2.02 of this Agreement. “Original Sale Date” means the date on which the Original Sale is effected.

Related to Hypothetical Tax Basis

  • Hypothetical Tax Liability means, with respect to any Taxable Year, the Hypothetical Federal Tax Liability for such Taxable Year, plus the Hypothetical Other Tax Liability for such Taxable Year.

  • Net After-Tax Basis means, with respect to the Payments, either with or without reduction under subsection (a) (as applicable), the amount that would be retained by the Executive from such Payments after the payment of all Taxes.

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

  • 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).

  • 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.

  • After-Tax Basis means, with respect to any payment to be received, the amount of such payment increased so that, after deduction of the amount of all taxes required to be paid by the recipient calculated at the then maximum marginal rates generally applicable to Persons of the same type as the recipients with respect to the receipt by the recipient of such amounts (less any tax savings realized as a result of the payment of the indemnified amount), such increased payment (as so reduced) is equal to the payment otherwise required to be made.

  • 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.

  • 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.

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

  • 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 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.

  • Net Taxable Income has the meaning set forth in Section 4.01(b)(i).

  • 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.

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

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

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

  • 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.

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

  • Non-Stepped Up Tax Basis means, with respect to any Reference Asset at any time, the Tax basis that such asset would have had at such time if no Basis Adjustments had been made.

  • MUNICIPAL TAXABLE INCOME means the following:

  • Special Taxes means any and all present or future taxes, levies, imposts, deductions, charges or withholdings, or any liabilities with respect thereto, including those arising after the date hereof as result of the adoption of or any change in law, treaty, rule, regulation, guideline or determination of a Governmental Authority or any change in the interpretation or application thereof by a Governmental Authority but excluding, in the case of Lender, such taxes (including income taxes, franchise taxes and branch profit taxes) as are imposed on or measured by Lender’s net income by the United States of America or any Governmental Authority of the jurisdiction under the laws under which Lender is organized or maintains a lending office.

  • Adjusted gross income means that term as defined in section 62 of the internal revenue code of 1986.

  • After-Tax Contributions means amounts withheld from an Employee’s Compensation pursuant to a Salary Reduction Agreement after all applicable state and federal taxes have been deducted. Such amounts are withheld for purposes of purchasing one or more of the Benefit Package Options available under the Plan.

  • Corporate Taxpayer Return means the federal and/or state and/or local Tax Return, as applicable, of the Corporate Taxpayer filed with respect to Taxes of any Taxable Year.

  • Distribution Taxes means any Taxes incurred solely as a result of the failure of the Intended Tax Treatment of the Restructuring, the Contribution or the Distribution.

  • Floating Profit/Loss means current profit/loss on Open Positions calculated at the current Quotes.