New Partnership Audit Rules definition

New Partnership Audit Rules means the provisions of subchapter C of chapter 63 of subtitle F of the Code (i.e., Sections 6221 through 6241 of the Code), as in effect for tax years beginning after December 31, 2017, and any Treasury Regulations promulgated thereunder.
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New Partnership Audit Rules has the meaning set forth in Section 6.6.
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Examples of New Partnership Audit Rules in a sentence

  • To the extent that the Partnership Representative does not make an election to apply the alternative method provided by Section 6226 of the Code (or any analogous provision of state or local tax law), the Partnership Representative shall have the authority and discretion to determine the portion of any imputed underpayment (within the meaning of the New Partnership Audit Rules) allocable to each Member.

  • Each Member agrees that any payment by the Company of a partnership-level tax imposed with respect to the New Partnership Audit Rules shall be treated as paid with respect to such Member.

  • Each Member hereby agrees to indemnify and hold harmless the Company, the other Members, the Partnership Representative and the Manager from and against any liability (including any liability for partnership-level taxes imposed with respect to the New Partnership Audit Rules) with respect to income attributable to or distributions or other payment to such Member.

  • If distributions are insufficient to satisfy any amounts apportioned to any Partner with respect to the New Partnership Audit Rules, such Partner shall indemnify and hold harmless the General Partner, the Partnership Representative and the Partnership for such amounts, which indemnity obligation shall survive the exchange or assignment of an Interest and the termination of this Agreement.

  • The Tax Matters Member shall have no authority pursuant to its designation under Section 8.3 hereof to exercise any authority with respect to matters subject to the New Partnership Audit Rules.

  • If the Company comes to be subject to the New Partnership Audit Rules for any period, the Company’s Partnership Representative for purposes of the New Partnership Audit Rules will be the Tax Matters Member.

  • The Tax Matters Member will not elect into application of the New Partnership Audit Rules under Section 1101(g)(4) of the 2015 Budget Act or any similar provision relating to the New Partnership Audit Rules without the prior written consent of PME.

  • Nothing herein shall diminish, limit or restrict the rights of any Member under the New Partnership Audit Rules.

  • The Partnership’s Partnership Representative for purposes of the New Partnership Audit Rules will be the General Partner or such other Partner or eligible third party as the General Partner may designate in writing.

  • The Tax Matters Member will, on a reasonably timely basis, provide the Company with copies of all notices received by the Tax Matters Member in connection with any proceeding or potential adjustment relating to the Company that is subject to the New Partnership Audit Rules.