Ineligible Trust definition

Ineligible Trust means a trust whose ownership of any S Corporation Shares would cause the termination of that corporation's election to be taxed under subchapter S of the Code.
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Ineligible Trust means a trust whose ownership of any S Corporation Shares would cause the termination of that corporation's election to be taxed under subchapter S of the Code. 2. "Net Income" means income, as defined in Code Sec. 643(b). 3. "S Corporation Shares" means shares of any stock of a corporation that then operates or that the Trustees shall deem likely to operate in the future under an election to have its earnings taxed directly to its stockholders under subchapter S of the Code. 49 <PAGE> 4. The "QSST Termination Date" means the earlier of the date on which the beneficiary of a trust under this section dies and the date on which such trust no longer holds any S Corporation Shares. E.
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Ineligible Trust means a trust whose ownership of any S Corporation Shares would cause the termination of that corporation’s election to be taxed under subchapter S of the Code.
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Examples of Ineligible Trust in a sentence

  • Ineligible Trust: • Irrevocable Trust• Blind Trusts• Life Estates Program Eligibility • Fixed and ARM Agency Loans• Elite Jumbo• FHA and VA• Texas 50 (A)(6) are eligible Refer to Plaza’s program guidelines for specific eligibility.

  • The Trustee (excluding, however, any Interested Trustee) shall manifest its selection of the form in which it shall hold any S Corporation Shares by written notice to all persons who would be eligible or entitled at the time of such writing to receive income from the Ineligible Trust that otherwise would hold such S Corporation Shares.

  • If so directed by the relevant Asset Trust Beneficiary, the amount due to pay for a Re-allocated Receivable will be paid either from available amounts standing to the credit of the relevant Asset Trust Reinvestment Account which are owed to the relevant Asset Trust Beneficiary or from a Contribution; and (b) until an Investment is made as contemplated in the preceding section, the relevant Purchased Receivable will remain part of Eligible Trust Property or the Ineligible Trust Property (as applicable).

  • It is expected that after the date of this Prospectus, new special purpose vehicles will be incorporated which will make a contribution pursuant to the terms of the Asset Trust Deed to fund either the purchase of Eligible Purchased Receivables as Eligible Trust Beneficiaries or Ineligible Purchased Receivables as Ineligible Trust Beneficiaries.

  • The proceeds of such Investment will constitute part of the Available Eligible Trust Distribution Amount or Available Ineligible Trust DistributionAmount to be allocated by the Asset Trustee in accordance with the terms of the Asset Trust Deed.

  • For the avoidance of doubt, the Seller Beneficiary will solely be beneficially entitled to an interest in respect of the Eligible Trust and not the Ineligible Trust.

  • If so requested the Ineligible Trust Beneficiaries or the Eligible Trust Beneficiaries (as applicable) will make an Investment and any such Eligible Purchased Receivable or Ineligible Purchased Receivable (as applicable) will, upon such Investment, cease to form part of the Eligible Trust Property and will instead be held by the Asset Trustee as part of Ineligible Trust Property (or vice versa, as applicable).

  • The Series 2012 VFN Beneficiary, the Series 2017-1 Beneficiary, the Series 2017-2 Issuer and the Seller Beneficiary are or will be Eligible Trust Beneficiaries and the ITN Issuer is an Ineligible Trust Beneficiary.

  • In the event there is more than one income beneficiary of an Ineligible Trust (defined below), the Trustee shall divide the S Corporation Shares that will be held under this paragraph into separate trusts, based on each beneficiary's interest in the income of the Ineligible Trust that otherwise would have held those shares.

  • All Eligible Trust Property is held by the Asset Trustee for the Eligible Trust Beneficiaries as tenants in common and all Ineligible Trust Property is held by the Asset Trustee for the Ineligible Trust Beneficiaries as tenants in common.

Related to Ineligible Trust

  • Eligible Trust means - (i) a trust created by or in pursuance of the provisions of any law which is for the time being in force in any State, or (ii) a trust, the properties of which are vested in a treasurer under the Charitable Endowments Act 1890 (Act 6 of 1890), or (iii) a religious or charitable trust which is administered or controlled or supervised by or under the provisions of any law, which is for the time being in force relating to religious or charitable trusts or, (iv) any other trust, being an irrevocable trust, which has been created for the purpose of or in connection with the endowment of any property or properties for the benefit or use of the public or any section thereof, or (v) a trust created by a will which is valid and has become effective, or (vi) any other trust, being an irrevocable trust, which has been created by an instrument in writing and includes `depository' within the meaning of Clause(e) of Sub-section (1) of Section 2 of The Depository Act, 1996;

  • Applicable Trust Has the meaning specified in the recitals hereto.

  • Ineligible Account means an Account that at the time of determination is not an Eligible Account.

  • Ineligible Holder is defined in Section 4.8(c).

  • Ineligible Institution has the meaning assigned to such term in Section 9.04(b).

  • Charitable trust means any trust provided for in Section 8.2(a)(ii) and Section 8.3(a).

  • Ineligible means that the individual obtained the checks and clearances as described in sections 5n and 5q and is not considered appropriate to obtain a license, to be a member of the household of a group child care home or family child care home, or to be a child care staff member due to violation of section 5n, 5q, or 5r.

  • Eligible interests means interests or memberships.

  • Eligible Transferee means and include a commercial bank, financial institution or other "accredited investor" (as defined in Regulation D of the Securities Act).

  • Income trust means a trust or an entity, including corporate and non-corporate entities, the securities of which entitle the holder to net cash flows generated by an underlying business or income-producing properties owned through the trust or by the entity;

  • Collateral Interest Holder means the entity so designated in the Transfer Agreement.

  • Ineligible Receivables shall have the meaning specified in subsection 2.05(a).

  • the Macfarlane Trust means the charitable trust, established partly out of funds provided by the Secretary of State to the Haemophilia Society, for the relief of poverty or distress among those suffering from haemophilia;

  • Charitable Trustee means each Person, unaffiliated with the Trust and a Prohibited Owner, that is appointed by the Trust from time to time to serve as a trustee of a Charitable Trust as provided by Section 8.3(a).

  • Deemed Partnership Interest Value means, as of any date with respect to any class of Partnership Interests, the Deemed Value of the Partnership Interests of such class multiplied by the applicable Partner's Percentage Interest of such class.

  • the Trust Fund means the Bond(s) referred to in the First Schedule to the Declaration of Trust and the property from time to time representing the same (and also includes any other property which may become Trust Property as a result of any loan to the Trustees or any addition by way of gift or any accumulation of income).

  • Ineligible Loan Each Loan other than an Eligible Loan.

  • Eligible Investment means any investment that at the time of its acquisition is one or more of the following:

  • Eligible Citizen means a Person qualified to own interests in real property in jurisdictions in which any Group Member does business or proposes to do business from time to time, and whose status as a Limited Partner the General Partner determines does not or would not subject such Group Member to a significant risk of cancellation or forfeiture of any of its properties or any interest therein.

  • Disqualified Institutions means those Persons (the list of all such Persons, the “Disqualified Institutions List”) that are (i) identified in writing by the Borrower to the Administrative Agent prior to the initial allocation of the Loans to be funded on the Closing Date, (ii) competitors of the Borrower and its Subsidiaries (other than bona fide fixed income investors or debt funds) that are identified in writing by the Borrower from time to time or (iii) Affiliates of such Persons set forth in clauses (i) and (ii) above (in the case of Affiliates of such Persons set forth in clause (ii) above, other than bona fide fixed income investors or debt funds) that are either (a) identified in writing by the Borrower from time to time or (b) clearly identifiable on the basis of such Affiliate’s name; provided, that, to the extent Persons are identified as Disqualified Institutions in writing by the Borrower to the Administrative Agent after the Closing Date pursuant to clauses (ii) or (iii)(a), the inclusion of such Persons as Disqualified Institutions shall not retroactively apply to prior assignments or participations in respect of any Loan under this Agreement. Until the disclosure of the identity of a Disqualified Institution to the Lenders generally by the Administrative Agent in writing, such Person shall not constitute a Disqualified Institution for purposes of a sale of a participation in a Loan (as opposed to an assignment of a Loan) by a Lender; provided, that no disclosure of the Disqualified Institutions List (or the identity of any Person that constitutes a Disqualified Institution), in part or in full, to the Lenders shall be made by the Administrative Agent without the prior written consent of the Borrower. Notwithstanding the foregoing, the Borrower, by written notice to the Administrative Agent, may from time to time in its sole discretion remove any entity from the Disqualified Institutions List (or otherwise modify such list to exclude any particular entity), and such entity removed or excluded from the Disqualified Institutions List shall no longer be a Disqualified Institution for any purpose under this Agreement or any other Loan Document.

  • Ineligible Receivable shall have the meaning specified in subsection 2.04(d)(iii).

  • Eligible Account Any of (i) an account or accounts maintained with a federal or state chartered depository institution or trust company the short-term unsecured debt obligations of which (or, in the case of a depository institution or trust company that is the principal subsidiary of a holding company, the debt obligations of such holding company) have the highest short-term ratings of each Rating Agency at the time any amounts are held on deposit therein, or (ii) an account or accounts in a depository institution or trust company in which such accounts are insured by the FDIC or the SAIF (to the limits established by the FDIC or the SAIF, as applicable) and the uninsured deposits in which accounts are otherwise secured such that, as evidenced by an Opinion of Counsel delivered to the Trustee and to each Rating Agency, the Certificateholders have a claim with respect to the funds in such account or a perfected first priority security interest against any collateral (which shall be limited to Permitted Investments) securing such funds that is superior to claims of any other depositors or creditors of the depository institution or trust company in which such account is maintained, or (iii) a trust account or accounts maintained with (a) the trust department of a federal or state chartered depository institution or (b) a trust company, acting in its fiduciary capacity or (iv) any other account acceptable to each Rating Agency. Eligible Accounts may bear interest, and may include, if otherwise qualified under this definition, accounts maintained with the Trustee.

  • Eligible Investor Either (i) a Qualified Institutional Buyer that is purchasing for its own account or for the account of a Qualified Institutional Buyer to whom notice is given that the offer, sale or transfer is being made in reliance on Rule 144A or (ii) an Institutional Accredited Investor.

  • Investment Account As defined in Section 3.12(a).