IRS Agreement definition
Examples of IRS Agreement in a sentence
For purposes of this Article IX, an "AXP Excess Issue" shall mean an AXP Issue the Tax liability for which (including any related interest, penalties and additions to Tax) exceeds any proposed deficiency set forth in the RAR with respect to such AXP Issue or, if less, the amount of any deficiency with respect to such AXP Issue in an agreement with the IRS reached during Appellate proceedings ("IRS Agreement").
Ameriprise's liability for an AXP Excess Issue shall be an amount equal to the excess, if any, of the actual liability for Taxes (including any related interest, penalties and additions to Tax) with respect to such AXP Excess Issue over the proposed deficiency in the RAR or IRS Agreement, as the case may be.
The seeking of or entering into any IRS Agreement meeting the requirements of this Section 5.16 (or any resulting Dividend Deficiency Amount, Section 5.16 Expenses Amount or Section 5.16 Interest/Penalties Amount) shall not constitute a circumstance, event, occurrence, change or effect that would constitute a Cornerstone Material Adverse Effect.
If Cornerstone shall have obtained an IRS Agreement pursuant to this Section 5.16 requiring the payment of any amount to the IRS, whether denominated as taxes, a payment in lieu of taxes, a penalty, or interest (including, without limitation, the interest payment required under Section 860 of the Code) (collectively, the "Section 5.16 Interest/Penalties"), Cornerstone shall pay such Section 5.16 Interest/Penalties in accordance with the IRS Agreement and provide Colonial evidence of such payment.
The term of this MOU is four (4) years from the effective date of the 2005 IRS Agreement, and may be terminated consistent with that agreement.
Excess Issue shall be an amount equal to the excess, if any, of the actual liability for Taxes (including any related interest, penalties and additions to Tax) with respect to such AXP Excess Issue over the proposed deficiency in the RAR or IRS Agreement, as the case may be.
The term of this MOD is four (4) years from the effective date of the 2005 IRS Agreement, and may be terminated consistent with that agreement.
The IRS Agreement does not in any way limit or prohibit the performance of the Company under the terms of this Agreement.
The Company represents and warrants that it and BioMed have made in full all payments required to be made to date, under the IRS Agreement; and is not required to make any estimated payments.
Without limiting the foregoing, the Section 5.16 Interest/Penalties also shall include any amount payable to any state or local taxing authority as a result of the matters covered by the IRS Agreement.