Partnership Audit Provisions definition

Partnership Audit Provisions means Title XI, Section 1101, of the Bipartisan Budget Act of 2015, P.L. 114-74 (together with any subsequent amendments thereto, Treasury Regulations promulgated thereunder, and published administrative interpretations thereof, and any comparable provisions of state or local tax law).
Sample 1Sample 2Sample 3
Partnership Audit Provisions means Code Sections 6221 through 6241, as may be amended, and including any Treasury Regulations or other administrative guidance promulgated by the IRS thereunder or successor provisions and any comparable provision of non-U.S. or U.S. state or local law.
Sample 1Sample 2Sample 3
Partnership Audit Provisions means the Bipartisan Budget Act of 2015 and Sections 6221-6231 of the Code (and the Regulations promulgated thereunder), as amended thereunder.
Sample 1Sample 2Sample 3

Examples of Partnership Audit Provisions in a sentence

  • The Manager shall cause the Company to take all necessary actions required by Law to designate the Corporation as the “tax matters partner” of the Company within the meaning of Section 6231 of the Code (as in effect prior to repeal of such section pursuant to the Revised Partnership Audit Provisions) with respect any Taxable Year beginning on or before December 31, 2017.

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

  • Imputed Underpayment Amounts also shall include any imputed underpayment within the meaning of Section 6225 of the Partnership Audit Provisions paid (or payable) by any entity treated as a partnership for U.S. federal income tax purposes in which the Company holds (or has held) a direct or indirect interest other than through entities treated as corporations for U.S. federal income tax purposes to the extent that the Company bears the economic burden of such amounts, whether by applicable Law or contract.

  • The Partnership Representative is authorized to take, and shall determine in its sole discretion whether or not the Company will take, such actions and execute and file all statements and forms on behalf of the Company that are approved by the Manager and are permitted or required by the applicable provisions of the Partnership Audit Provisions (including a “push-out” election under Section 6226 of the Code or any analogous election under state or local tax Law).

  • Pursuant to the Revised Partnership Audit Provisions, USCo shall be designated and may, on behalf of the Company, at any time, and without further notice to or consent from any Member, act as the “partnership representative” of the Company (within the meaning given to such term in Section 6223 of the Code) (the “Partnership Representative”) for purposes of the Code.

  • The “Partnership Representative” (as such term is defined under Partnership Audit Provisions) of the Company shall be selected by the Manager with the initial Partnership Representative being the Corporation.

  • The Company (i) has not made any election under the Partnership Audit Provisions to have them apply to the Company with respect to any period (or portion thereof) before January 1, 2018, and (ii) has not made any election to opt out of the Partnership Audit Provisions with respect to any period (or portion thereof) after December 31, 2017.

  • Notwithstanding the immediately preceding sentence, the Tax Matters Representative shall, to the fullest extent permitted by applicable law, elect out of the Partnership Audit Provisions (including by making an election pursuant to Code Section 6221(b), as added by the Partnership Audit Provisions).(c) Reimbursement.

  • For any tax year that the Company is subject to the New Partnership Audit Provisions, the Member that would otherwise act as the “tax matters partner” will serve as the Company’s “partnership representative” (the “ Partnership Representative”) within the meaning of new Code Section 6223(a).

  • PaulActing Assistant Secretary for Tax Policy Acting Chief CounselDepartment of the Treasury Internal Revenue Service1500 Pennsylvania Avenue, N.W. 1111 Constitution Avenue, N.W.Washington, DC 20220 Washington, DC 20224Re: Request for Delay in Effective Date on Partnership Audit Provisions in the Bipartisan Budget Act of 2015Dear Messrs.


More Definitions of Partnership Audit Provisions

Partnership Audit Provisions means Code Sections 6221 through 6241, as they may be amended, and including any Treasury Regulations or other administrative guidance promulgated by the IRS thereunder or successor provisions and any comparable provision of non-U.S. or U.S. state or local law.
Sample 1Sample 2Sample 3
Partnership Audit Provisions means Subchapter C of Chapter 63 of the Code, as modified by Section 1101 of the Bipartisan Budget Act of 2015, Pub. L. No. 114-74, and any successor statutes thereto or Treasury Regulations promulgated thereunder.
Sample 1Sample 2Sample 3
Partnership Audit Provisions means the Bipartisan Budget Act of 2015 and Sections 6221-6231 of the Code and the Treasury Regulations promulgated thereunder (and comparable provisions of state and local Tax Law).
Sample 1Sample 2Sample 3
Partnership Audit Provisions has the meaning set forth in Section 8.5(b).
Sample 1

Related to Partnership Audit Provisions

  • Partnership at will means a partnership in which the partners have not agreed to remain partners until the expiration of a definite term or the completion of a particular undertaking.

  • Partnership Agreement means the Amended and Restated Agreement of Limited Partnership of the Operating Partnership dated as of , 2011, as the same may be amended, modified or restated from time to time.

  • Partnership Act means the Delaware Revised Uniform Limited Partnership Act, 6 Del. C. §§ 17-101, et seq., as it may be amended from time to time, and any successor to such statute.