Hypothetical Tax Rate definition

Hypothetical Tax Rate means for any given taxable period, the highest hypothetical combined U.S. federal, state and local tax rates for an individual or corporation resident in the higher of (a) the State of California or (b) the City and the State of New York, in each case taking into account the deductibility of state and local income taxes as applicable at the time for United States federal income tax purposes.
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Hypothetical Tax Rate means for any given taxable period, the highest hypothetical combined U.S. federal, state and local tax rates for an individual or corporation resident in the City and the State of New York, taking into account the deductibility of state and local income taxes as applicable at the time for United States federal income tax purposes.
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Hypothetical Tax Rate means the greater of (a) the combined marginal U.S. federal, state and local tax rate for an individual resident in New York, New York and (b) the highest combined marginal U.S. federal, state and local tax rate for a corporation that conducts no activities other than the activities of Holdings, the Borrower and their Subsidiaries, in each case applicable to income and gain attributable to the Borrower and any entity in which Borrower directly or indirectly owns an interest, taking into account (where relevant) the holding period of assets held by the Borrower and any entity in which Borrower directly or indirectly owns an interest, the taxable year in which such income or gain is recognized, and the character of such income or gain, at the time, for U.S. federal income tax purposes.
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Examples of Hypothetical Tax Rate in a sentence

  • For example, if a Corporate Holder receives a $100,000 Distribution and the Non-DRD Amount with respect to such Distribution is $100,000 (i.e., the Corporation has $0 E&P), the DRD percentage with respect to such Distribution under Section 243 of the Code is 50%, the Hypothetical Tax Rate is 28%, and there are $0 of the interest and penalties described in clause (y) above, then the DRD Gross-Up Amount would equal $19,444.44, computed as follows: (28% x ($100,000 x 50%)) / (1 - .28).

  • For example, if a Corporate Holder receives a $100,000 Distribution, the Non-DRD Amount with respect to such Distribution is $100,000 (i.e., the Corporation has $0 E&P), the DRD percentage with respect to such Distribution under Section 243 of the Code is 65%, the Hypothetical Tax Rate is 24%, and there are $0 of the interest and penalties described in clause (y) above, then the DRD Gross-Up Amount would equal $20,526.32, computed as follows: (24% x ($100,000 x 65%)) / (1 - .24).


More Definitions of Hypothetical Tax Rate

Hypothetical Tax Rate means the sum of (i) the highest U.S. federal marginal income tax rate applicable to corporations (as measured for the applicable tax year in which the relevant DRD Gross-Up Distribution or Section 1059 Gross-Up Distribution is to be made) and (ii) 5.00%.
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Hypothetical Tax Rate means the greater of (a) the highest combined marginal U.S. federal, state and local tax rate for an individual resident in Michigan, New York City or California (whichever is higher) and (b) the highest combined marginal U.S. federal, state and local tax rate for a corporation that conducts no activities other than the activities of the Borrower and its Subsidiaries, in each case applicable to income and gain attributable to the Borrower and its Subsidiaries, taking into account (where relevant) the holding period of assets held by the Borrower and its Subsidiaries, the taxable year in which such income or gain is recognized by the Borrower and its Subsidiaries and the character of such income or gain, at the time for U.S. federal income tax purposes.
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Hypothetical Tax Rate means, for any taxable year, the greater of the highest marginal rate of combined federal, state and local income tax (including any Medicare contribution taxes imposed on net investment income) payable by (i) an individual resident in New York City and(ii) a corporation resident in New York City whose sole assets are the membership interests of the Parent that are held by such corporation, in each case taking into account the particular character of the income involved (e.g., capital gain or ordinary income) and taking into account the deductibility of state and local income taxes in computing federal income tax liability.
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Hypothetical Tax Rate means the sum of (i) the highest U.S. federal marginal income tax rate applicable to corporations (as measured, with respect to a Distribution subject to Section (3)(f) hereof, for the applicable tax year in which such Distribution is made) and (ii) 3.00%.
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Hypothetical Tax Rate means the greater of (a) the highest combined marginal U.S. federal, state and local tax rate for an individual resident in New York City (taking into account any applicable deduction under Section 199A of the Code) and (b) the highest combined marginal U.S. federal, state and local tax rate for a corporation that conducts no activities other than the activities of the Borrower and its Subsidiaries, in each case applicable to income and gain attributable to the Borrower and its Subsidiaries, taking into account (where relevant) the holding period of assets held by the Borrower and its Subsidiaries, the taxable year in which such income or gain is recognized by the Borrower and its Subsidiaries and the character of such income or gain, at the time for U.S. federal income Tax purposes.
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Related to Hypothetical Tax Rate

  • Tax Rate means the rate imposed under section 51 of the income tax act of 1967, 1967 PA 281, MCL 206.51, for the tax year in which the tax year of the taxpayer for which the credit is being computed begins.

  • Rollback tax rate means the rate that will produce last year’s maintenance and operation tax levy (adjusted) from this year’s values (adjusted) multiplied by 1.08 plus a rate that will produce this year’s debt service from this year’s values (unadjusted) divided by the anticipated tax collection rate.

  • Effective tax rate means the rate that will produce last year’s total tax levy (adjusted) from this year’s total taxable values (adjusted). “Adjusted” means lost values are not included in the calculation of last year’s taxes and new values are not included in this year’s taxable values.

  • Floating Allocation Percentage means, with respect to any Monthly Period, the percentage equivalent (which percentage shall never exceed 100%) of a fraction, the numerator of which is the Invested Amount as of the last day of the preceding Monthly Period (or with respect to the first Monthly Period, the Initial Invested Amount) and the denominator of which is the greater of (1) the sum of (x) the total amount of Principal Receivables in the Trust at the end of the day on such date (or with respect to the first Monthly Period, at the end of the day on the Closing Date) and (y) the principal amount on deposit in the Excess Funding Account as of the end of the day on such date and (2) the sum of the numerators used to calculate the Series Percentages (as such term is defined in the Agreement) with respect to Finance Charge Receivables or Defaulted Receivables, as applicable, for all Series then outstanding; provided, however, that with respect to any Monthly Period in which an Addition Date occurs and the Servicer need not make daily deposits of Collections into the Collection Account, the denominator in (x) above shall be the Average Principal Balance; provided further, however, that with respect to any Monthly Period in which an Addition Date occurs and the Servicer is required to make daily deposits of Collections into the Collection Account, the denominator in (x) above shall be (1) for the period from and including the first day of such Monthly Period to but excluding the related Addition Date, the aggregate amount of Principal Receivables in the Trust at the end of the day on the last day of the prior Monthly Period and (2) for the period from and including the related Addition Date to and including the last day of such Monthly Period, the aggregate amount of Principal Receivables in the Trust at the end of the day on the related Addition Date.

  • Assumed Tax Rate means the highest effective marginal combined U.S. federal, state and local income tax rate for a Fiscal Year prescribed for an individual or corporate resident in New York, New York (taking into account (a) the nondeductiblity of expenses subject to the limitation described in Section 67(a) of the Code and (b) the character (e.g., long-term or short-term capital gain or ordinary or exempt income) of the applicable income, but not taking into account the deductibility of state and local income taxes for U.S. federal income tax purposes). For the avoidance of doubt, the Assumed Tax Rate will be the same for all Partners.

  • Floating Profit/Loss in a CFD shall mean current profit/loss on Open Positions calculated at the current Quotes (added any commissions or fees if applicable).

  • Effective State average tax rate means the average of effective county tax rates for all counties.

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

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

  • Taxable Rate means, with respect to a Taxable Period, the product of (i) the average interest rate on the Bonds during such period and (ii) 1.54.

  • 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.

  • Allocation Year Means (i) the period commencing on the Closing Date and ending on December 31, 2006, (ii) any subsequent period commencing on January 1 and ending on the following December 31, or (iii) any portion of the period described in clause (ii) for which the Company is required to allocate Profits, Losses and other items of Company income, gain, loss or deduction pursuant to Article V.

  • Adjusted Capital Account Balance means, with respect to each Partner, the balance in such Partner’s Capital Account adjusted (i) by taking into account the adjustments, allocations and distributions described in Treasury Regulations Sections 1.704-1(b)(2)(ii)(c)(4), (5) and (6); and (ii) by adding to such balance such Partner’s share of Partnership Minimum Gain and Partner Nonrecourse Debt Minimum Gain, determined pursuant to Treasury Regulations Sections 1.704-2(g) and 1.704-2(i)(5), and any amounts such Partner is obligated to restore pursuant to any provision of this Agreement or by applicable Law. The foregoing definition of Adjusted Capital Account Balance is intended to comply with the provisions of Treasury Regulations Section 1.704-1(b)(2)(ii)(d) and shall be interpreted consistently therewith.