RJRN Federal Tax Liability definition

RJRN Federal Tax Liability means, with respect to any taxable period, the sum of the RJRN Tax Group's Federal Tax liability and any interest, penalties and other additions to such taxes for such taxable period, computed as if the RJRN Tax Group were not part of the Holdings Consolidated Group, but rather were a separate affiliated group of corporations filing a consolidated Federal Tax return pursuant to Section 1501 of the Code; provided, however, that transactions with members of the Nabisco Tax Group or Holdings shall be reflected in accordance with applicable provisions of the consolidated return regulations governing intercompany transactions. Without limiting the generality of the foregoing, such computation shall be made (i) without regard to the income, deductions (including, without limitation, net operating loss and capital loss deductions) and credits in any taxable period of any member of the Holdings Consolidated Group that is not a member of the RJRN Tax Group, (ii) by taking account of any Tax Asset of the RJRN Tax Group in accordance with the principles of Section 3.04(d), (iii) with regard to tax carryforwards and tax carrybacks (including, without limitation, carryforwards and carrybacks of net operating losses or capital losses) of any member of the RJRN Tax Group, (iv) as though the highest rate of tax specified in Section 11(b) of the Code were the only rates set forth in that subsection, (v) by taking account of the positions, elections and accounting methods reflected in the consolidated Federal Tax returns, as amended and as finally adjusted, of the Holdings Consolidated Group, and (vi) without gain, if any, attributable to the Internal Distribution.
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RJRN Federal Tax Liability means, with respect to any taxable period, the sum of the RJRN Tax Group's Federal Tax liability and any interest, penalties and other additions to such taxes for such taxable period, computed as if the RJRN Tax Group were not and never were part of the Holdings Consolidated Group, but rather were a separate affiliated group of corporations filing a consolidated Federal Tax return pursuant to Section 1501 of the Code; provided, however, that transactions with members of the Nabisco Tax Group or Holdings shall be reflected according to the provisions of the consolidated return regulations, promulgated under the Code, governing intercompany transactions. Without limiting the generality of the foregoing, such computation shall be made (i) without regard to the income, deductions (including, without limitation, net operating loss and capital loss deductions) and credits in any taxable period of any member of the Holdings Consolidated Group that is not a member of the RJRN Tax Group, (ii) by taking account of any Tax Asset of the RJRN Tax Group in accordance with the principles of Section 3.04(d), (iii) with regard to tax carryforwards and tax carrybacks (including, without limitation, carryforwards and carrybacks of net operating losses or capital losses) of any member of the RJRN Tax Group, (iv) as though the highest rate of tax specified in Section 11(b) of the Code were the only rates set forth in that subsection, (v) by taking account of the positions, elections and accounting methods reflected in the consolidated Federal Tax returns, as amended and as finally adjusted, of the Holdings Consolidated Group, and (vi) without gain, if any, attributable to the Internal Distribution.
Sample 1
RJRN Federal Tax Liability means, with respect to any taxable period, the sum of the RJRN Tax Group's Federal Tax liability and any interest, penalties and other additions to such taxes for such taxable period, computed as if the RJRN Tax Group were not part of the Holdings Consolidated Group, but rather were a separate affiliated group of corporations filing a consolidated Federal Tax return pursuant to Section 1501 of the Code; provided, however, that transactions with members of the Nabisco Tax Group or Holdings shall be reflected in accordance with applicable provisions of the consolidated return regulations governing intercompany transactions. Without limiting the generality of the foregoing, such computation shall be made (i) without regard to the income, deductions (including, without limitation, net operating loss and capital loss deductions) and credits in any taxable period of any member of the Holdings
Sample 1

Related to RJRN Federal Tax Liability

  • Hypothetical Tax Liability means, with respect to any Taxable Year, the Hypothetical Federal Tax Liability for such Taxable Year, plus the Hypothetical Other Tax Liability for such Taxable Year.

  • Assumed Tax Liability means, with respect to any Member, an amount equal to the excess of (i) the product of (A) the Distribution Tax Rate multiplied by (B) the estimated or actual cumulative taxable income or gain of the Company, as determined for federal income tax purposes, allocated to such Member (or its predecessor) for full or partial Fiscal Years commencing on or after January 1, 2021, less prior losses of the Company allocated to such Member (or its predecessor) for full or partial Fiscal Years commencing on or after January 1, 2021, in each case, as determined by the Manager and to the extent such prior losses are available to reduce such income over (ii) the cumulative Tax Distributions made to such Member after the closing date of the IPO pursuant to Sections 4.01(b)(i), 4.01(b)(ii) and 4.01(b)(iii) and, if applicable with respect to such Fiscal Year, pursuant to Section 4.1(a) of the Previous LLC Agreement; provided that, in the case of the Corporation, such Assumed Tax Liability (x) shall be computed without regard to any increases to the tax basis of the Company’s property pursuant to Sections 734(b) or 743(b) of the Code and (y) to the extent permitted under the Credit Agreements and applicable Law, shall in no event be less than an amount that will enable the Corporation to meet both its tax obligations and its obligations pursuant to the Tax Receivable Agreement for the relevant Taxable Year; provided further that, in the case of each Member, and for the avoidance of doubt, such Assumed Tax Liability shall take into account any Code Section 704(c) allocations (including “reverse” 704(c) allocations) to the Member.

  • Actual Tax Liability means, with respect to any Taxable Year, the liability for Covered Taxes of the Corporation (a) appearing on Tax Returns of the Corporation for such Taxable Year and (b) if applicable, determined in accordance with a Determination (including interest imposed in respect thereof under applicable law).

  • 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.

  • 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.

  • State premium tax liability means any liability

  • Consolidated federal income tax return means a consolidated return filed for federal income tax purposes pursuant to section 1501 of the Internal Revenue Code.

  • Tax Liabilities means all liabilities for Taxes.

  • Income Tax Return means any Tax Return relating to Income Taxes.

  • After-imposed Federal tax means any new or increased Federal excise tax or duty, or tax that was exempted or excluded on the contract date but whose exemption was later revoked or reduced during the contract period, on the transactions or property covered by this contract that the Contractor is required to pay or bear as the result of legislative, judicial, or administrative action taking effect after the contract date. It does not include social security tax or other employment taxes.

  • council tax benefit means council tax benefit under Part 7 of the SSCBA; “couple” has the meaning given by paragraph 4;

  • Pre-Closing Tax Return has the meaning set forth in Section 7.1(a).

  • Swiss Federal Tax Administration means the tax authorities referred to in article 34 of the Swiss Withholding Tax Act.

  • Federal Tax means any Tax imposed under Subtitle A of the Code.

  • After-relieved Federal tax means any amount of Federal excise tax or duty, except social security or other employment taxes, that would otherwise have been payable on the transactions or property covered by this contract, but which the Contractor is not required to pay or bear, or for which the Contractor obtains a refund or drawback, as the result of legislative, judicial, or administrative action taking effect after the contract date.

  • Income Tax Returns means all Tax Returns relating to Income Taxes.

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

  • Tax means any tax, levy, impost, duty or other charge or withholding of a similar nature (including any penalty or interest payable in connection with any failure to pay or any delay in paying any of the same).

  • Pre-Closing Tax Returns has the meaning set forth in Section 4.02(b).

  • 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.

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

  • Non-Income Tax Return means any Tax Return relating to Taxes other than Income Taxes.

  • Transaction Tax Deductions means, to the extent Tax deductible for Income Tax purposes, all compensation attributable to payments by a Company or Company Subsidiary on or prior to the Closing Date, including employee transaction-related bonuses, change of control payments, and severance payments, resulting from or related to the consummation of the Contemplated Transactions that are charged to Sellers as part of the Transaction Expenses.

  • Assumed State and Local Tax Rate means the tax rate equal to the sum of the products of (x) the Corporation’s income tax apportionment factor for each state and local jurisdiction in which the Corporation files income or franchise tax returns for the relevant Taxable Year and (y) the highest corporate income and franchise tax rate in effect for such Taxable Year for each such state and local jurisdiction in which the Corporation files income tax returns for each relevant Taxable Year.

  • Consolidated Return means any Tax Return relating to Income Taxes filed pursuant to Section 1502 of the Code, or any comparable combined, consolidated, or unitary group Tax Return relating to Income Taxes filed under state or local tax law which, in each case, includes IDT and at least one subsidiary.

  • 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 .