Examples of Lessor Partnership in a sentence
As this article seeks to demonstrate, the analysis was important not only in dealing with the submission of the appellants that the Commissioner was bound by the terms of the public rulings to treat the Lessor Partnership as the owner of plant, but also to the Court’s approach to the issue of abuse of power.
The highest concentrations of Co are detected in albite-calcsilicate rocks (up to 2190 ppm) and albitite (up to 1445 ppm) between the albite-chlorite end members, as well as in biotite-calcsilicate rocks (up to 2150 ppm) and mineralized mica schists (up to 1880 ppm) when close to the muscovite node (Figs.
Such PV System and the related Customer Agreement have been assigned to and are owned by the Lessor Partnership or Partnership, to which the Managing Member has an Equity Interest, free and clear of all liens and encumbrances, except for liens permitted under the applicable Project Documents of the applicable Subject Fund, as applicable.
Respondent shall discuss its experience with each of these agencies, as applicable.
It should be noted that the Court did state that there was another reason why the principle of unfairness had no application in the circumstances; namely that none of the rulings referred to could really be said to extend to the situation of the Lessor Partnership: Bellinz (FFC) 98 ATC 4634, 4645.
Tax Equity Structure Partnership / Lessor Partnership (Subject Fund) Partnership Managing Member / Lessor Partnership Managing Member Funded Subsidiaries (Subject Fund and Managing Member, if any) Lessee Full Cash-Sweep Fund, Partial Cash-Sweep Fund or Non-Cash Sweep Fund Investor(s) [***] [***] [***] [***] [***] [***] [***] [***] [***] [***] [***] [***] [***] [***] [***] [***] [***] [***] [***] [***] [***] Annex 1 [***] Confidential treatment has been requested for the bracketed portions.
Both His Honour at first instance, and the Full Court on appeal, went to some length to explain why none of the rulings referred to by the appellants related to the particular financing arrangement in question and therefore did not operate by force of the TAA to bind the Commissioner to regard the Lessor Partnership as the “owner” for the purposes of s 54 of the ITAA36.
It is submitted that it is this conclusion which underpins the decision in Bellinz not only in respect of the appellants’ argument that the rulings were binding on the Commissioner to require him to treat the Lessor Partnership as the owner of the plant, but also in respect of the submission based upon abuse of power.
SCHEDULE 1.1(B) CHANGE IN CONTROL Partnership Managing Member / Lessor Managing Member / Borrower Subsidiary (Other Non-Financed Structure) Equity Interests Owned as of date related Partnership or Lessor Partnership becomes a Subject Fund [***] [***] [***] [***] [***] [***] [***] [***] [***] [***] [***] [***] [***] [***] Schedule 1.1(B) [***] Confidential treatment has been requested for the bracketed portions.