Partially Taxable Member definition

Partially Taxable Member means (i) a Member whose allocable income from the Company includes amounts that (A) are generally exempt from federal, state, and local income taxes and franchise taxes and (B) are taxable to such Member despite such Member’s tax-exempt status, and (ii) a Member that is taxed as a partnership but whose partners or members include both taxable and tax-exempt entities.
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Examples of Partially Taxable Member in a sentence

  • To each Taxable Member and each Partially Taxable Member, an amount equal to the Company’s Tax Expense Recovery Income multiplied by an allocation factor that is the quotient of such Member’s Percentage Interest divided by the total Percentage Interest of all Taxable and Partially Taxable Members.

  • Notwithstanding Section 10.1, except to the extent that PLR-104930-07 has been amended or supplemented in any enforceable manner as described in Section 11.8(b), any amendment to Section 6.1(a), 6.2(a), 6.2(g) or to the definition of Excess Tax Expense Recovery Income, Partially Taxable Member, Member’s Tax Expense Recovery Income Distributable Amount, Taxable Member, Tax-Exempt Member, or Tax Expense Recovery Income shall require the consent of each of the Voting Members.

Related to Partially Taxable Member

  • casual taxable person means a person who occasionally undertakes transactions involving supply of goods or services or both in the course or furtherance of business, whether as principal, agent or in any other capacity, in the taxable territory where he has no fixed place of business;

  • Deconsolidation shall have the meaning provided in the Recitals.

  • State premium tax liability means any liability

  • Consolidated federal taxable income means the consolidated taxable income of an affiliated group of corporations, as computed for the purposes of filing a consolidated federal income tax return, before consideration of net operating losses or special deductions. "Consolidated federal taxable income" does not include income or loss of an incumbent local exchange carrier that is excluded from the affiliated group under division (A)(1) of this section.

  • Post-Deconsolidation Period means any taxable period beginning after the date of a Deconsolidation Event.

  • Net Taxable Income has the meaning set forth in Section 4.01(b)(i).

  • MUNICIPAL TAXABLE INCOME means the following:

  • Taxable REIT Subsidiary means, as to Host REIT and with regard to Host REIT’s taxable years commencing after December 31, 2000, any of Fernwood, Rockledge or any other TRS of Host REIT, and, as to any Subsidiary REIT, any TRS of such Subsidiary REIT.

  • Base taxable value means the agreed value specified in a resolution or interlocal agreement under Subsection 17C-1-102(8) from which tax increment will be collected.

  • Post-Distribution Tax Period means a Tax period beginning and ending after the Distribution Date.

  • Consolidated Return means a Tax Return filed with respect to Federal Income Taxes for the Consolidated Group.

  • Contributing Member shall have the meaning set forth in Section 3.2(b).

  • Tax Year means a period beginning with 6th April in one year and ending with 5th April in the next;

  • Contributing Employer means any employer other than a reimbursing employer or rated governmental employer.

  • Local Subdivision Contribution means the Local Subdivision financial share used for the sole and express purpose for paying or reimbursing the costs certified to the Director under this Agreement for completion of the project.

  • Agreement combined tax rate means the sum of the tax rates:

  • Taxable Allocation means, with respect to any Series, the allocation of any net capital gains or other income taxable for federal income tax purposes to a dividend paid in respect of such Series.

  • Pre-Deconsolidation Period means any taxable period beginning on or prior to the applicable Deconsolidation Date.

  • Taxable means either:

  • Tax Liability means the total taxes due to a municipal corporation for the taxable year, after allowing any credit to which the taxpayer is entitled, and after applying any estimated tax payment, withholding payment, or credit from another taxable year.

  • Combined Tax Return means a Tax Return filed in respect of U.S. federal, state, local or non-U.S. income Taxes for a Combined Group, or any other affiliated, consolidated, combined, unitary, fiscal unity or other group basis (including as permitted by Section 1501 of the Code) Tax Return of a Combined Group.

  • Tax Benefit Payment is defined in Section 3.1(b) of this Agreement.

  • Tax return preparer means any individual described in Section 7701(a)(36) of the Internal Revenue Code and 26 C.F.R. 301.7701-15 .

  • Tax Attribute means a net operating loss, net capital loss, unused investment credit, unused foreign Tax credit, excess charitable contribution, general business credit, research and development credit, earnings and profits, basis, or any other Tax Item that could reduce a Tax or create a Tax Benefit.

  • Rollback tax rate means the rate that will produce last year’s maintenance and operation tax levy (adjusted) from this year’s values (adjusted) multiplied by 1.08 plus a rate that will produce this year’s debt service from this year’s values (unadjusted) divided by the anticipated tax collection rate.

  • Hypothetical Tax Liability means, with respect to any Taxable Year, the liability for Taxes of the Corporation (or the Partnerships, but only with respect to Taxes imposed on the Partnerships and allocable to the Corporation) using the same methods, elections, conventions and similar practices used on the relevant Corporation Return but using the Non-Stepped Up Tax Basis instead of the tax basis reflecting the Basis Adjustments of the Adjusted Assets and excluding any deduction attributable to Imputed Interest.