Imputed Tax Underpayment definition

Imputed Tax Underpayment has the meaning set forth in Section 5.5(c)(i).

Imputed Tax Underpayment is defined in Section 5.9.

Imputed Tax Underpayment has the meaning set forth in Section 8.7(e)(i).

Examples of Imputed Tax Underpayment in a sentence

• The Partnership Representative shall use commercially reasonable efforts to pursue available procedures to reduce any Imputed Tax Underpayment on account of any Partner’s tax status and each Partner shall promptly comply with any reasonable request made by the Partnership Representative to accommodate such procedures.

• Each Member agrees to amend its U.S. federal income tax return(s) to include (or reduce) its allocable share of the Company’s income (or losses) resulting from an IRS Adjustment and pay any tax due with such return as required under Section 6225(c)(2) of the Code, even if an Imputed Tax Underpayment liability of the Company or IRS Adjustment occurs after the Member’s withdrawal from the Company.

• The Company Representative shall use commercially reasonable efforts to pursue available procedures to reduce any Imputed Tax Underpayment on account of any Member’s tax status.

• The Managing Member may in its sole discretion elect under Section 6226 of the New Partnership Audit Procedures to cause the Company to issue adjusted Internal Revenue Service Schedules K-1 (or such other form as applicable) reflecting a Member’s shares of any IRS Adjustment for the Adjustment Year as an alternative to the Company’s payment of an Imputed Tax Underpayment for any tax year.

• Notwithstanding any other provision of this Agreement, each Member (or former Member) shall bear any tax, interest, penalty or “imputed underpayment” under Code Section 6225 (if applicable) or similar amount resulting from the final resolution of any audit adjustment (the “Imputed Tax Underpayment”) to the extent such Imputed Tax Underpayment is attributable to such Member (or former Member) or results from the status of such Member (or such former Member) as a Member in the Reviewed Year.

• The Partnership Representative shall use reasonable efforts to pursue available procedures to reduce any Imputed Tax Underpayment on account of any Member’s tax status.

• The Partnership Representative shall use commercially reasonable efforts to pursue available procedures to reduce any Imputed Tax Underpayment on account of any Member’s tax status and each Member shall promptly comply with any reasonable request made by the Partnership Representative to accommodate such procedures.

• Each Partner agrees to amend its U.S. federal income tax return(s) to include (or reduce) its allocable share of the Partnership’s income (or losses) resulting from an IRS Adjustment and pay any tax due with such return as required under Section 6225(c)(2) of the Code even if an Imputed Tax Underpayment liability of the Partnership or IRS Adjustment occurs after the Partner’s withdrawal from the Partnership.

• The Partnership Representative shall use commercially reasonable efforts to pursue available procedures to reduce any Imputed Tax Underpayment on account of any Partner’s tax status and each Partner shall promptly comply with any reasonable request made by the Partnership Representative to accommodate such procedures.

• The Partnership Representative shall use commercially reasonable efforts to pursue available procedures to reduce any Imputed Tax Underpayment on account of any Member’s tax status.

More Definitions of Imputed Tax Underpayment

Imputed Tax Underpayment has the meaning set forth in Section 3.8(d).

Imputed Tax Underpayment has the meaning set forth in Section 7.04(c). “Indemnified Party” has the meaning set forth in Section 4.07(a). “Indirect Transfer” means any Transfer of any equity securities of (i) any Member which does not hold any Securities of any Person other than Units or (ii) any Affiliate of such Member, which Affiliate does not hold any Securities of any Person other than Equity Securities, directly or indirectly, of such Member. “Individual Agreement” has the meaning set forth in the definition of “Termination for Cause”. “Initial Capital Contributions” has the meaning set forth in Section 3.01(a). “Initial Public Offering” means any underwritten initial public offering of Securities of the Company or any of its Subsidiaries pursuant to an effective registration statement filed under the Securities Act. “Initial Subscribers” has the meaning set forth in Section 3.04(c). “IRS Adjustment” has the meaning set forth in Section 7.04(c). “Issuance Notice” has the meaning set forth in Section 3.04(a). “Liquidator” has the meaning set forth in Section 9.03(b). “Magnetar Demand Right” has the meaning set forth in Section 11.02(a). “Magnetar Indemnitors” has the meaning set forth in Section 4.07(d). “Magnetar Managers” has the meaning set forth in Section 4.01(a)(i)(A). “Magnetar Members” means each of (i) Appgate Investors, (ii) the Affiliates and Permitted Transferees of Appgate Investors or any other Magnetar Member who hold or own Units and (xi) their respective Affiliates or Permitted Transferees who hold or own Units (provided that no such Permitted Transferee shall be a “Magnetar Member” pursuant to subsection (x) or (xi) of this