Non-Stepped Up Tax Basis definition
Non-Stepped Up Tax Basis means, with respect to any Reference Asset at any time, the Tax basis that such asset would have had at such time if no Basis Adjustments had been made.
Non-Stepped Up Tax Basis means, with respect to any IPO Date Asset at any time, the Tax basis that such asset would have had at such time if no Pre-IPO Basis Adjustments had been made.
Non-Stepped Up Tax Basis in respect of any Exchanging Member means, with respect to any asset at any time, the Tax basis that such asset would have had at such time if no Basis Adjustment had been made in respect of such Exchanging Member.
Examples of Non-Stepped Up Tax Basis in a sentence
Thus, for example, in determining the Hypothetical Tax Liability of Corporate Taxpayer the taxable income of Corporate Taxpayer shall be determined by treating Holdings as having sold the applicable Reference Asset for its fair market value, recovering any basis applicable to such Reference Asset (using the Non-Stepped Up Tax Basis), while the Actual Tax Liability of Corporate Taxpayer would be determined by recovering the actual Tax basis of the Reference Asset that reflects any Basis Adjustments.
More Definitions of Non-Stepped Up Tax Basis
Non-Stepped Up Tax Basis means, with respect to any Reference Asset at any time, (a) if the Reference Asset was transferred in the IPCo Transfer (or any asset that is “substituted basis property” under Section 7701(a)(42) of the Code with respect thereto), a Tax basis of zero dollars and (b) with respect to any other Reference Asset, the Tax basis that such Reference Asset would have had at such time if there had been no Basis Adjustment with respect to such Reference Asset.
Non-Stepped Up Tax Basis means in respect of an LLC Unit Holder, with respect to any Reference Asset at any time, the Tax basis that such asset would have had at such time if no Basis Adjustments had been made in respect of such LLC Unit Holder.
Non-Stepped Up Tax Basis means, with respect to any Reference Asset at any time, the Tax basis that such asset would have had at such
Non-Stepped Up Tax Basis in respect of any Exchanging TRA Member means, with respect to any asset at any time, the Tax basis that such asset would have had at such time if no Basis Adjustment had been made in respect of such Exchanging TRA Member.
Non-Stepped Up Tax Basis means, with respect to any Reference Asset at any time, the Tax basis that such asset would have had at such time if no Basis Adjustments had been made and assuming that the Tax basis of any Reference Asset (other than cash or cash equivalents) of Eve immediately prior to the Pre-Closing Reorganization is zero.
Non-Stepped Up Tax Basis means, with respect to any Reference Asset at the time of the Reorganization that is depreciable or amortizable for United States federal income tax purposes, the Tax basis that such Reference Asset would have had if the Blocker Transferred Basis at the time of the Reorganization was equal to zero.
Non-Stepped Up Tax Basis means the Tax basis that the assets held directly or indirectly by the Corporation (or any other member of the consolidated, combined or unitary group of which the Corporation is a member) would have had if no Boot Basis Adjustments had been made.