Imputed Underpayment definition

Imputed Underpayment means an imputed underpayment under Section 6225 of the Code, as amended by the BBA.

Imputed Underpayment has the meaning assigned to such term in Section 9.4(a).

Imputed Underpayment shall have the meaning set forth in Section 12.7.2(a).

Examples of Imputed Underpayment in a sentence

• If a Member fails to pay any amount that it is required to pay the Company in respect of an Imputed Underpayment Share within such ten (10) day period, that amount shall be treated as a loan to the Member, bearing interest at ten (10) percent annually (which interest shall increase the Member’s Imputed Underpayment Share).

• Any Member not permitted to treat its Imputed Underpayment Share as a loan due to the provisions of the previous sentence shall pay any Imputed Underpayment Share within ten (10) days after the date of the notice referred to in the first sentence of this Section 4.4(e)(ii) of this Annex C.

• If the Member fails to repay the loan upon demand, the full balance of the loan shall be immediately due (including accrued but unpaid interest) and the Company shall have the right to collect the balance in any manner it determines, including by reducing future distributions to that Member; provided, however, that no Member may have any Imputed Underpayment Share treated as a loan to the extent it would violate Section 402 of the Xxxxxxxx-Xxxxx Act of 2002.

• To the extent the Company is liable for any Imputed Underpayment, the Company shall determine the liability of the Members for a share of such Imputed Underpayment, taking into account the Members’ Units and the status and actions of the Members (including those described in Code Section 6225(c)) (such share, an “Imputed Underpayment Share”).

More Definitions of Imputed Underpayment

Imputed Underpayment is defined in Section 4.4(d) of this Xxxxx X.

Imputed Underpayment means the amount determined by applying the applicable [State] income tax rate, as determined under subsection C(4)(a), to all partnership adjustments made by a Partnership Level Audit properly apportioned to [State].

Imputed Underpayment is defined in Section 6.26(b).

Imputed Underpayment means any “imputed underpayment” (as determined under Section 6225 of the Code (as enacted by the Budget Act, or a corresponding provision of state or local law)) paid (or payable) by the Company as a result of an adjustment with respect to any Company item, including any interest, adjustment to tax or penalties with respect to any such adjustment.

Imputed Underpayment is defined in Section 5.9.1.

Imputed Underpayment is defined in Section 6225(b) of the Code.

Imputed Underpayment is defined in Section 7.5(b).