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 the Corporate Taxpayer the taxable income of the Corporate Taxpayer shall be determined by treating OpCo 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 the Corporate Taxpayer would be determined by recovering the actual Tax basis of the Reference Asset that reflects any Basis Adjustments.

• Thus, for example, in determining the Hypothetical Tax Liability of the entity, the taxable income of the entity shall be determined by treating the entity as having sold the asset for its fair market value, recovering any basis applicable to such asset by using the Non-Stepped Up Tax Basis, while the actual Tax liability of the entity would be determined by recovering the actual Tax basis of the asset that reflects any Exchange Basis Adjustments..

• The Actual Tax Liability for each Taxable Year shall be calculated by assuming that each Adjusted Asset had a tax basis equal to its Non-Stepped Up Tax Basis as of immediately before each applicable Exchange (for purposes of measuring the Basis Adjustment resulting from such Exchange).

• Thus, for example, in determining the Hypothetical Tax Liability of the entity, the taxable income of the entity shall be determined by treating the entity as having sold the asset for its fair market value, recovering any basis applicable to such asset by using the Non-Stepped Up Tax Basis, while the actual Tax liability of the entity would be determined by recovering the actual Tax basis of the asset that reflects any Exchange Basis Adjustments.

• It is the intention of the parties for the Charter Member to pay A/N 50% of the additional Covered Taxes that the Charter Group would have been required to pay on Tax Returns that have actually been filed had those Tax Returns been computed by reference to Non-Stepped Up Tax Basis for the Exchange Assets and excluding any deductions attributable to Imputed Interest and this Agreement shall be interpreted in accordance with such intention.

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 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 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 in respect of any TRA Party means, with respect to any Exchange Reference Asset in respect of such TRA Party at any time, the Tax basis that such asset would have had at such time if no Exchange Basis Adjustments in respect of such TRA Party had been made.

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.