IRS Adjustment definition

IRS Adjustment has the meaning set forth in Section 5.5(c).

IRS Adjustment has the meaning set forth in Section 10.3.C hereof.

IRS Adjustment is defined in Section 10.2.3.

Examples of IRS Adjustment in a sentence

• In accordance with Section 6225 of the Code, the Partnership shall pay an imputed underpayment as calculated under Section 6225(b) of the Code with respect to the IRS Adjustment, including interest and penalties (“Imputed Tax Underpayment”) in the Adjustment Year.

• Provided the election described in Section 5.5(b) above is not in effect, in the case of any adjustment by the IRS in the amount of any item of income, gain, loss, deduction, or credit of the Partnership or any Partner’s distributive share thereof (“IRS Adjustment”), the Partnership Representative shall respond to such IRS Adjustment in accordance with (c)(i) or (c)(ii) below.

• Alternatively, with the approval of the General Partners, the Partnership Representative may elect under Section 6226 of the Code to cause the Partnership to issue adjusted Internal Revenue Service Schedules “K-1” (or such other form as applicable) reflecting a Partner’s shares of any IRS Adjustment.

• Also, the NOL deduction is limited to 80% of taxable income for taxable years beginning after December 31, 2017.If you are filing an amended return due to an IRS adjustment to your federal return, also check the IRS Adjustment box at the top of page 1 of Form F-1.

• 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 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.

• Section 5.12.6 Alternatively, the Company Representative may elect under section 6226 of the Code as implemented under the 2015 Act 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.

• Also, attach all schedules, forms, and attachments required to file a complete return.If the return is being amended to take an NOL carryback deduction, also check the NOL Carryback box at the top of page 1 of Form F-1.If you are filing an amended return due to an IRS adjustment to your federal return, also check the IRS Adjustment box at the top of page 1 of Form F-1.

• Provided the election described in Section 10.2.2 is not in effect, in the case of any adjustment by the IRS in the amount of any item of income, gain, loss, deduction, or credit of the Company or any Member’s distributive share thereof (“IRS Adjustment”), the Partnership Representative, acting at the direction of NBM or the Board of Managers, as applicable, shall respond to such IRS Adjustment in accordance with either 10.2.3(a) or (b).

• Within 30 days of the acceptance or other final determination of any IRS Adjustment, the Buyer shall notify the Representatives of the IRS Adjustment.

More Definitions of IRS Adjustment

IRS Adjustment has the meaning set forth in Section 11.1(e).

IRS Adjustment has the meaning set forth in Section 3.8(d).

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