Residual Profit definition

Residual Profit and “Residual Loss” shall mean, for any fiscal year, the net taxable income or loss, as the case may be, of the Partnership for such fiscal year, as determined for federal income tax purposes, as modified by Regulations Section 1.704-1(b)(2)(iv), except that Residual Profit and Residual Loss shall not include:
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Residual Profit means when routine costs are identified and tested under one of the other transfer pricing methods and residual profits are split according to the transactional profit split method;
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Residual Profit is defined in Section 5.01(h).
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Examples of Residual Profit in a sentence

  • The provisions of this paragraph (c)(3) are illustrated by the following example.Example—Application of Residual Profit Split.

  • The Arm’s Length Range is between % and %, and the Median of the Arm’s Length Range is %.• Residual Profit Split MethodThe TPM is the residual profit split method.

  • Taxpayer’s Three-Year Rolling Average operating margin must be between % and % (the Arm’s Length Range.)• Residual Profit Split MethodThe TPM is the residual profit split method.

  • For small claims, the taxpayer may simply deduct 25% of the Qualifying Residual Profit as the marketing royalty.

  • The small claims treatment is available if the Qualifying Residual Profit are below 1 Million GPB as well as if the qualifying residual profits are below 3 Million GPB and certain further requirements are met.

  • A student may transfer credit earned in the adult education program to a secondary school to count toward the units of credit required for a state high school diploma earned through the regular course of study at a high school, if for each unit being transferred, the student has spent a minimum of 120 hours in class time in that subject at that level and the teacher was properly certified to teach the course.

  • Item 4: Residual Profit and Loss Report the portion of comprehensive profit and loss that cannot be specifically attributed to existing or new positions.

  • The EMEA Region The EMEA region operates five types of company being: ► Residual Profit Entities: These are fully integrated operations in the sense that all relevant group functions sit within them as opposed to just marketing, distribution and sales.

  • For larger claims, a de minimis relief is available where the taxpayer is reasonably convinced that the marketing royalty is less than 10% of the Qualifying Residual Profit, which implies that the deduction of a marketing royalty is not required (HMRC (2012), pp.

  • Consequentially, returns to routine functions which exceed 10% automatically fall inside the Patent Box.Finally, the third step comprises deducting a notional marketing royalty for the use of marketing intangibles (e.g. trademarks) from the Qualifying Residual Profit as such intangible assets are explicitly excluded from the Patent Box.


More Definitions of Residual Profit

Residual Profit or “Residual Loss” means Profits or Loss minus Financial Accounts Profits or Loss.
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Residual Profit equals the (i) the Residual Cash, less (ii) all Asset Management Fees and Asset Management Catch-Up Fees and other costs and expenses payable upon liquidation by OPC REIT, the QDII and US L.P. (excluding any promote interests paid upon liquidation), less (iii) amounts accrued or paid to the holders of any shares of preferred stock of OPC REIT in accordance with the terms of such preferred shares, less (iv) the sum of the U.S. taxes, using the Agreed Applicable Tax Rate that would be attributable to such fees, costs and expenses that are expected to be non-deductible in computing the After Tax Residual Profit and the U.S. taxes using the Agreed Applicable Tax Rate that would be payable on the 10% Annual Return (as contemplated by Section 10.1(a)).
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Residual Profit equals the (i) the Residual Cash, plus (ii) the promote interests paid to any JV Operating Partner pursuant to a Joint Venture with the Partnership, less (iii) all Asset Management Fees and Asset Management Catch-Up Fees and other costs and expenses payable upon liquidation by the General Partner, the QDII and US L.P. (excluding any promote interests paid upon liquidation), less (iv) amounts accrued or paid to the holders of any shares of preferred stock of the General Partner in accordance with the terms of such preferred shares, less (v) the sum of the U.S. taxes, using the Agreed Applicable Tax Rate that would be attributable to such fees, costs and expenses that are expected to be non-deductible in computing the After Tax Residual Profit and the U.S. taxes using the Agreed Applicable Tax Rate that would be payable on the 10% Annual Return (as contemplated by Section 5.2(b)(i)).
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Residual Profit has the meaning set forth in Section 3.5(b).
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Residual Profit has the meaning set forth in subparagraph 1(c) of Exhibit B.
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Related to Residual Profit

  • Operating Profit means the excess of Gross Revenues over the following deductions (“Deductions”) incurred by Manager, on behalf of Owner, in operating the Hotel:

  • Residual Auction Revenue Rights means incremental stage 1 Auction Revenue Rights created within a Planning Period by an increase in transmission system capability, including the return to service of existing transmission capability, that was not modeled pursuant to Operating Agreement, Schedule 1, section 7.5 and the parallel provisions of Tariff, Attachment K- Appendix, section 7.5 in compliance with Operating Agreement, Schedule 1, section 7.4.2 (h) and the parallel provisions of Tariff, Attachment K-Appendix, section 7.4.2(h), and, if modeled, would have increased the amount of stage 1 Auction Revenue Rights allocated pursuant to Operating Agreement, Schedule 1, section 7.4.2 and the parallel provisions of Tariff, Attachment K-Appendix, section 7.4.2; provided that, the foregoing notwithstanding, Residual Auction Revenue Rights shall exclude: 1) Incremental Auction Revenue Rights allocated pursuant to Tariff, Part VI; and 2) Auction Revenue Rights allocated to entities that are assigned cost responsibility pursuant to Operating Agreement, Schedule 6 for transmission upgrades that create such rights.

  • Non-Profit means a qualified non-profit entity as defined in Section 42(h)(5)(C), subsection 501(c)(3) or 501(c)(4) of the IRC and organized under Chapter 617, F.S., if a Florida Corporation, or organized under similar state law if organized in a jurisdiction other than Florida, to provide housing and other services on a not-for-profit basis, which owns at least 51 percent of the ownership interest in the Development held by the general partner or managing member entity, which shall receive at least 25 percent of the Developer fee, and which entity is acceptable to federal and state agencies and financial institutions as a Sponsor for affordable housing, as further described in Rule 67-48.0075, F.A.C.

  • Floating Profit/Loss means current profit/loss on Open Positions calculated at the current Quotes (added any commissions or fees if applicable).

  • Operating Revenues means, for any, period, the gross revenues arising from the ownership and operation of the Properties during such period, including proceeds of any business interruption or rental loss insurance and amounts released from reserves, but specifically excluding Capital Proceeds, Capital Contributions and proceeds of Indebtedness.

  • COGS means the cost of goods sold as determined in accordance with U.S.GAAP;

  • Gross Income from Operations means, during any period, all sustainable income as reported on the financial statements delivered by Borrower in accordance with this Agreement, computed in accordance with GAAP, derived from the ownership and operation of the Property from whatever source during such period, including (i) Rents from Tenants that are in occupancy, open for business and paying full contractual rent without right of offset or credit, (ii) utility charges, (iii) escalations, (iv) forfeited security deposits, (v) interest on credit accounts, (vi) service fees or charges, (vii) license fees, (viii) parking fees, (ix) rent concessions or credits, (x) income from vending machines, (xi) business interruption or other loss of income or rental insurance proceeds, (xii) other required pass-throughs and (xiii) interest on Reserve Funds, if any, but excluding (i) Rents from month-to-month Tenants, Tenants during a free-rent period, or Tenants that are included in any Bankruptcy Action, (ii) sales, use and occupancy or other taxes on receipts required to be accounted for by Borrower to any Governmental Authority, (iii) refunds and uncollectible accounts, (iv) sales of furniture, fixtures and equipment, (v) Insurance Proceeds (other than business interruption or other loss of income or rental insurance), (vi) Awards, (vii) unforfeited security deposits, (viii) utility and other similar deposits and (ix) any disbursements to Borrower from the Reserve Funds, if any. Gross income shall not be diminished as a result of the Security Instrument or the creation of any intervening estate or interest in the Property or any part thereof.

  • Operating Margin means the incremental adjustments, measured in megawatts, required in PJM Region operations in order to accommodate, on a first contingency basis, an operating contingency in the PJM Region resulting from operations in an interconnected Control Area. Such adjustments may result in constraints causing Transmission Congestion Charges, or may result in Ancillary Services charges pursuant to the PJM Tariff. Operating Margin Customer:

  • Residual Receipts means for each calendar year, the amount by which Gross Revenue exceeds Annual Operating Expenses.

  • Residual disinfectant concentration (“C” in CT cal- culations) means the concentration of disinfectant measured in mg/l in a representative sample of water.

  • Residual Metered Load means all load remaining in an electric distribution company’s fully metered franchise area(s) or service territory(ies) after all nodally priced load of entities serving load in such area(s) or territory(ies) has been carved out.

  • Program Income means gross in- come earned by the recipient that is di- rectly generated by a supported activ- ity or earned as a result of the award (see exclusions in § 215.24(e) and (h)). Program income includes, but is not limited to, income from fees for serv- ices performed, the use or rental of real or personal property acquired under federally-funded projects, the sale of commodities or items fabricated under an award, license fees and royalties on patents and copyrights, and interest on loans made with award funds. Interest earned on advances of Federal funds is not program income. Except as other- wise provided in Federal awarding agency regulations or the terms and conditions of the award, program in- come does not include the receipt of principal on loans, rebates, credits, dis- counts, etc., or interest earned on any of them.