Separate Tax Benefit definition

Separate Tax Benefit of a Member means the increase in the tax liability of the Consolidated Group which would arise if the Net Losses of such Member were excluded from the Consolidated Return, and computed without regard to the AMT and MTC.
Separate Tax Benefit has the meaning assigned to that term pursuant to Section 3 below.
Separate Tax Benefit of a Subsidiary shall mean the amount by which the Tax liability shown on the Parent Consolidated Return was reduced as a result of a tax credit or of a Separate Taxable Loss or the carryforward or carryback of a Separate Taxable Loss attributable to such Subsidiary from any Subsidiary Taxable Period. The amount of reduction of Tax liability on a Parent Consolidated Return attributable to a Subsidiary shall be computed by calculating the difference between (i) the Tax liability of the Parent Consolidated Group computed as a flat tax at the highest marginal rate for each taxing system provided under the Code and (ii) the Tax liability of the Parent Consolidated Group excluding the items of income, deduction, loss and credit attributable to the Subsidiary in question computed as a flat tax at the highest marginal rate for each taxing system provided under the Code. The ordering and allocation of the use of credits, net operating losses and capital losses of Subsidiaries will be determined under the Code, the regulations thereunder and the generally accepted procedures of tax accounting. Notwithstanding the foregoing, the computation provided in clause (ii) above will be made based only on the items included for purposes of making the computation provided in clause (i) above; no additional losses or credits of other Subsidiaries are to be considered in making the computation provided in clause (ii).

Examples of Separate Tax Benefit in a sentence

  • For each taxable period to which the Master Agreement is applicable, MEH shall utilize the calculation made by Edison International under the Master Agreement of the amount of the Separate Tax Liability or Separate Tax Benefit (as such terms are defined in the Master Agreement) of EME and its Lower Tier Subsidiaries.

  • For each taxable period to which the Master Agreement is applicable, Mission Group shall utilize the calculation made by Parent under the Master Agreement of the amount of the Separate Tax Liability or Separate Tax Benefit (as such terms are defined in the Master Agreement) of each of the Subsidiaries.

  • If, for any such taxable period, (a) the aggregate of the Separate Tax Benefit of EME, if it has a Separate Tax Benefit, and the Separate Tax Benefits of each of its Lower Tier Subsidiaries which has a Separate Tax Benefit exceeds (b) the aggregate of the Separate Tax Liability of EME, if it has a Separate Tax Liability, and the Separate Tax Liabilities of each of its Lower Tier Subsidiaries which has a Separate Tax Liability, MEH shall pay to EME an amount equal to such excess.

  • With respect to each of the Companies which has Net Losses for any taxable period and each Subsidiary which has Net Losses for any taxable period, Parent shall calculate the increase in the tax liability of the Consolidated Group which would arise if the Net Losses of each such member of the Consolidated Group were excluded from the Consolidated Return for such taxable period (such amount being called herein, with respect to each such person, a "Separate Tax Benefit").

  • If, for any such taxable period, (a) the aggregate of the Separate Tax Benefit of a Company, if it has a Separate Tax Benefit, and the Separate Tax Benefit of each of its Subsidiaries which has a Separate Tax Benefit exceeds (b) the aggregate of the Separate Tax Liability of such Company, if it has a Separate Tax Liability, and the Separate Tax Liability of each of its Subsidiaries which has a Separate Tax Liability, Parent shall pay to such Company an amount equal to such excess.

  • For each taxable period to which the Master Agreement is applicable, Mission Financial shall utilize the calculation made by SCEcorp under the Master Agreement of the amount of the Separate Tax Liability or Separate Tax Benefit (as such terms are defined in the Master Agreement) of Funding and its Subsidiaries.

  • Each of the Companies shall pay to Parent the amount by which (a) the aggregate of the Separate Tax Liability of such Company, if it has a Separate Tax Liability, and the Separate Tax Liability of each of its Subsidiaries which has a Separate Tax Liability exceeds (b) the aggregate of the Separate Tax Benefit of such Company, if it has a Separate Tax Benefit, and the Separate Tax Benefit of each of its Subsidiaries which has a Separate Tax Benefit.

  • With respect to each of the Companies which have Net Losses for any taxable year ending on or after December 31, 2014 and each Subsidiary in that Company’s Company Group which has Net Losses for any such taxable year, the Parent shall calculate the Separate Tax Benefit.

  • CMS shall invoice each Subsidiary and each Subsidiary shall pay to CMS any additional amount due, or receive payment from CMS for any overpayment or Separate Tax Benefit, based upon such reconciliation, within 15 days.

  • To the extent a Company Group has been overpaid by the Parent because its recomputed aggregated Separate Tax Benefit is less than previously computed, the Company shall repay the Parent and to the extent a Company Group’s Separate Tax Liability is reduced as a result of the recomputation it shall be repaid by the Parent.


More Definitions of Separate Tax Benefit

Separate Tax Benefit of a Subsidiary shall mean the amount by which the Group Tax Liability was reduced as a result of a tax credit or of a Separate Taxable Loss or the carryforward or carryback of a Separate Taxable Loss attributable to such Subsidiary. The amount of reduction of the Group Tax Liability on the Group's consolidated return attributable to a Subsidiary shall be computed by calculating the difference between (i) the Group Tax Liability and (ii) the hypothetical Group Tax Liability computed by excluding the items of income, deduction, loss and credit attributable to the Subsidiary in question. The ordering and allocation of the use of credits, net operating losses and capital losses of Subsidiaries will be determined under the Code, the regulations thereunder and the generally accepted procedures of tax accounting. Notwithstanding the foregoing, the computation provided in clause (ii) above will be made based only on the items included for purposes of making the computation provided in clause (i) above; no additional losses or credits of other Subsidiaries are to be considered in making the computation provided in clause (ii).

Related to Separate Tax Benefit

  • Net Tax Benefit has the meaning set forth in Section 3.1(b) of this Agreement.

  • Tax Benefit means any refund, credit, or other item that causes reduction in otherwise required liability for Taxes.

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

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

  • Income Tax Expense means, with respect to the Borrowers, for any period, the aggregate, without duplication, of all Taxes on the income of such Person for such period, whether current or deferred, determined on a Modified Consolidated Basis.

  • 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.

  • Tax Benefit Schedule is defined in Section 2.02 of this Agreement.

  • Tax Benefits means the net operating loss carryovers, capital loss carryovers, general business credit carryovers, alternative minimum tax credit carryovers and foreign tax credit carryovers, as well as any loss or deduction attributable to a “net unrealized built-in loss” within the meaning of Section 382 of the Code and the Treasury Regulations promulgated thereunder, of the Company or any of its Subsidiaries.

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

  • Pre-Tax Income means income, as determined by GAAP, prior to deduction of the Bonus Pool (as hereinafter defined) and income taxes, and if applicable, after the deduction of any bonus pool of a future officer bonus plan adopted by the Company relating to an applicable Award Year and adjustments approved by the Board as described herein.

  • Base Tax Year means the property tax levy year used

  • Pre-Distribution Tax Period means any taxable period (or portion thereof) that ends on or before the Distribution Date.

  • Tax Detriment means an increase in the Tax liability (or reduction in refund or credit or item of deduction or expense) of a taxpayer (or of the Affiliated Group of which it is a member) for any taxable period.

  • Net After-Tax Benefit means the Present Value of a Payment net of all federal state and local income, employment and excise taxes imposed on Executive with respect thereto, determined by applying the highest marginal rate(s) applicable to an individual for Executive’s taxable year in which the Change in Control occurs.

  • Separate Return means (a) in the case of any Tax Return of any member of the SpinCo Group (including any consolidated, combined or unitary return), any such Tax Return that does not include any member of the Parent Group and (b) in the case of any Tax Return of any member of the Parent Group (including any consolidated, combined or unitary return), any such Tax Return that does not include any member of the SpinCo Group.

  • 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-Tax Earnings means the Corporation's earnings before income taxes as reported in the Company's Consolidated Income Statement for each fiscal year of the Performance Period, excluding any non-cash charge incurred in accordance with accounting principles generally accepted in the United States of America (GAAP) for any restricted stock or restricted stock unit awards granted during the Performance Period and all options, restricted stock and other equity compensation granted to Directors during the Performance Period.

  • 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.

  • Cumulative Net Realized Tax Benefit for a Taxable Year means the cumulative amount of Realized Tax Benefits for all Taxable Years of the Corporate Taxpayer, up to and including such Taxable Year, net of the cumulative amount of Realized Tax Detriments for the same period. The Realized Tax Benefit and Realized Tax Detriment for each Taxable Year shall be determined based on the most recent Tax Benefit Schedule or Amended Schedule, if any, in existence at the time of such determination.

  • Tax Items shall have the meaning set forth in Section 6.4.A.

  • Book-Tax Disparity means with respect to any item of Contributed Property or Adjusted Property, as of the date of any determination, the difference between the Carrying Value of such Contributed Property or Adjusted Property and the adjusted basis thereof for federal income tax purposes as of such date. A Partner’s share of the Partnership’s Book-Tax Disparities in all of its Contributed Property and Adjusted Property will be reflected by the difference between such Partner’s Capital Account balance as maintained pursuant to Section 5.5 and the hypothetical balance of such Partner’s Capital Account computed as if it had been maintained strictly in accordance with federal income tax accounting principles.

  • 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).

  • Consolidated Income Tax Expense means, with respect to any Person for any period, the provision for federal, state, local and foreign income taxes of such Person and its Restricted Subsidiaries for such period as determined on a consolidated basis in accordance with GAAP.

  • Nonqualifying Income means any amount that is treated as gross income for purposes of Section 856 of the Code and which is not Qualifying Income.

  • Tax Payment means either the increase in a payment made by an Obligor to a Finance Party under Clause 12.2 (Tax gross-up) or a payment under Clause 12.3 (Tax indemnity).

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