Partnership Adjustment definition

Partnership Adjustment shall have the meaning set forth in Section 6.18(b)(i).

Partnership Adjustment means any adjustment to a partnership-related item.

Partnership Adjustment shall have the meaning set forth in Section 9.1(d).

Examples of Partnership Adjustment in a sentence

• The Company (or its designee) shall be the “partnership representative” (the “Partnership Representative”) in connection with any audit of such Affected Tax Return and shall serve as Partnership Representative pursuant to the terms of this Agreement and the Partnership Adjustment Procedures that apply to audits conducted pursuant to the Budget Act including notifying the IRS of its designation as such, as may be necessary or appropriate under the Budget Act.

• For all tax years prior to the tax year for which the Partnership Adjustment Procedures (as hereinafter defined) are first applicable to the Company, the Directors shall designate a Person as the “Tax Matters Member” of the Company in accordance with Section 6231(a)(7) of the Code (prior to amendment by the Budget Act (as hereinafter defined) and any regulations issued thereunder.

• The Manager shall determine whether to file a petition in Tax Court, cause the Company to pay the amount of the Partnership Adjustment or make the election under Code Section 6226 and notify the Partnership Representative in writing within ten (10) days of their receipt of notice of the NFPA of their recommended action or actions.

• A Partnership subject to a Partnership Level Audit making an election pursuant to subsection C(3)(a)(iii) shall, within one hundred eighty (180) days of the Final Determination Date, file a State Partnership Adjustment Report with the [State Agency], pay the additional [State] tax owed by Composite Returns Partners and Nonresident Partners, and withhold and remit the tax owed by Withholding Partners.

• Enter the balance on line 3.Line 4 - Fiduciary and Partnership Adjustment (Attach Schedule): If during the taxable year the estate or trust was a beneficiary of another estate or trust and is entitled to an adjustment from such other estate or trust, enter the amount of such adjustment on line 4.

More Definitions of Partnership Adjustment

Partnership Adjustment is determined with respect to the Company, the Partnership Representative shall promptly notify the Members of receipt of a notice of final partnership adjustment (“NFPA”). The Manager shall determine whether to file a petition in Tax Court, cause the Company to pay the amount of the Partnership Adjustment or make the election under Code Section 6226 and notify the Partnership Representative in writing within ten (10) days of their receipt of notice of the NFPA of their recommended action or actions.

Partnership Adjustment. (as defined in Section 6241(2) of the Code) is finally determined with respect to the Company and the Tax Representative has not caused the Company to make the election under Section 6226 of the Code, then (i) the Members shall take such actions requested by the Tax Representative, including filing amended tax returns and paying any tax due in accordance with Section 6225(c)(2) of the Code; (ii) the Members shall cooperate with the Tax Representative’s efforts to reduce any imputed underpayment with respect to such Partnership Adjustment and shall promptly provide any information reasonably requested by the Tax Representative in connection with such efforts; and (iii) any imputed underpayment (or Partnership Adjustment that does not give rise to an imputed underpayment) shall be apportioned among the Members of the Company for the Fiscal Year in which such Partnership Adjustment is finalized in such manner as may be required (as determined by the Tax Representative) so that, to the maximum extent possible, the tax and economic consequences of the Partnership Adjustment and any associated interest and penalties are borne by the Members (including between former and current Members) based upon their interests in the Company for the “Reviewed Year” (as defined in Section 6225(d)(1) of the Code).

Partnership Adjustment means an y adjustment in t he amount of an y partnership item of an electing large partnership.

Partnership Adjustment means any adjustment in

Partnership Adjustment. Any adjustment to any “partnership- related item”, as such term is defined in Code Section 6241(2), or any Partner’s distributive share thereof, in any case as described in any applicable Regulations or other guidance prescribed by the IRS. Pass-through Partner: A pass-through entity that holds an interest in the Partnership, including a partnership (as described in Treas. Reg. § 301.7701-2(c)(1) including a foreign entity that is classified as a partnership under Treas. Reg. § 301.7701-3(b)(2)(i)(A) or (c), an S corporation, a trust (other than a trust described in the next sentence) and a decedent’s estate. For purposes of this definition, a pass-through entity does not include a disregarded entity described in Treas. Reg. § 301.7701-2(c)(2)(i) or a trust that is wholly owned by only one Person, whether the grantor or another Person, and the trust reports the owner’s information to payors under Treas. Reg. § 1.671-4(b)(2)(i)(A). Reviewed Year: The Partnership taxable year to which a Partnership Adjustment relates.

Partnership Adjustment means any adjustment in the amount of any item of income, gain, loss, deduction, or credit of a partnership, or any partner’s distributive share thereof.

Partnership Adjustment means any adjust- ment in the amount of any item of income, gain, loss, deduction, or credit of a partner- ship, or any partner’s distributive share thereof.