Special Tax Considerations definition

Special Tax Considerations. United States Federal Income Taxation The following discussion supplements and, to the extent that it is inconsistent with, replaces the discussion contained in the accompanying Prospectus Supplement in the section entitled "United States Federal Income Tax Considerations". We intend to treat the Notes as qualifying as "variable rate debt instruments" for United States federal income tax purposes that pay interest at a single objective rate. Under the applicable Treasury regulations, if interest on a debt instrument is stated at a fixed rate for an initial period of one year or less followed by a variable rate that is either a qualified floating rate or an objective rate for a subsequent period, and the value of the variable rate on the issue date is within 25 basis points of the fixed rate, the two rates will be conclusively presumed to approximate each other and therefore will be treated as constituting a single qualified floating rate or objective rate. Under this rule, we intend to treat the Initial Interest Rate and the floating rate as a single objective rate. U.S. Holders should consult the discussion in the accompanying Prospectus Supplement in the section entitled "United States Federal Income Tax Considerations -- U.S. Holders - Floating Rate Notes" for a description of the material of the United States federal income tax consequences of the ownership and disposition of variable rate debt instruments. Alternatively, it is possible that the Internal Revenue Service (the "IRS") could assert that the Notes are subject to special rules governing "contingent payment debt instruments" ("CPDIs"). If the IRS were successful in this assertion, U.S. Holders would be required to accrue original issue discount income, subject to adjustments, at the "comparable yield" (which is the yield at which a fixed rate debt instrument would be issued by us that has terms and conditions similar to the Notes) of the Notes and any gain recognized with respect to the Notes generally would be treated as ordinary income. Prospective investors should consult their tax advisors regarding the tax consequences to them of purchasing the Notes, including the possibility that the Notes could be treated as CPDIs. Prospective investors should consult the summary describing the principal U.S. federal income tax consequences of the ownership and disposition of the Notes contained in the section called "United States Federal Tax Considerations" in the accompanying Prospectus Supplement.
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Special Tax Considerations. The owner and Joint Owner of a Contract, who are not spouses of each other, may incur gift and other taxes with respect to the Contract that would not otherwise be incurred if the Joint Owner and Owner were married to each other. Unmarried persons who wish to own the Contract jointly should consult with their tax advisor. The Contract provides that the Owner will be deemed to have contributed 100% of the purchase payments. Therefore, we will treat the Owner as the taxpayer with respect to ALL distributions made under the Contract while he or she is the Owner, whether or not a Joint Owner is also named. There are special tax rules that apply to IRA and other qualified contracts during both the Accumulation Period and Annuity Period governing distributions upon the death of the Owner. These rules are contained in provisions in the attached endorsements and supersede any other distribution rules contained in the Contract. The preceding provisions regarding the death of the Owner are intended to satisfy the distribution at death requirements of section 72(s) of the Internal Revenue Code of 1986, as amended. We reserve the right to amend this Contract by subsequent endorsement as necessary to comply with applicable tax requirements, if any, which are subject to change from time to time. Such additional endorsements, if necessary to comply with amended tax requirements, will be mailed to you and become effective within 30 days of mailing, unless you notify us in writing, within that time frame, that you reject the endorsement. ANNUITY AND SETTLEMENT OPTIONS
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Special Tax Considerations. Interest payable on the Notes will be treated as "qualified stated interest" for United States Federal income tax purposes, as it meets the specified criteria referenced in the prospectus supplement under the heading "United States Federal Income Tax Considerations-U.S. Holders-Floating Rate Notes." ANNEX B DELAWARE TRUSTEE SERVICE FEE SCHEDULE As specified in a separate fee agreement. ANNEX C ADMINISTRATOR SERVICE FEE SCHEDULE As specified in a separate fee agreement. ANNEX D AGENT NOTICE INFORMATION As specified in Schedule 1 to the Distribution Agreement attached to the Series Instrument as Exhibit E. ANNEX E COORDINATION AGREEMENT NOTICE INFORMATION If to Allstate Life, at Allstate Life Insurance Company 0000 Xxxxxxx Xxxx Northbrook, IL 60062 Attention: Secretary If to Global Funding, at Allstate Life Global Funding c/o AMACAR Pacific Corp. 0000 Xxxxxxxx Xxxxxxxxx, Suite 318 Charlotte, NC 28211 Attention: President If to the Funding Note Indenture Trustee, at X.X. Xxxxxx Trust Company, National Association 000 Xxxxx Xxxxxxx Xxxxxx, Xxxxxxx, XX 00000 Attention: Xxxxx Xxxxxxx If to the Trust, at Allstate Life Global Funding Trust c/o AMACAR Pacific Corp. 0000 Xxxxxxxx Xxxxxxxxx, Suite 318 Charlotte, NC 28211 Attention: President If to the Indenture Trustee, at X.X. Xxxxxx Trust Company, National Association 000 Xxxxx Xxxxxxx Xxxxxx, Xxxxxxx, XX 00000 Attention: Xxxxx Xxxxxxx
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Examples of Special Tax Considerations in a sentence

  • Special Tax Considerations for Non-U.S. StockholdersThe rules governing U.S. income taxation of non-resident alien individuals, foreign corporations, foreign partnerships and foreign trusts and estates (non-U.S. stockholders) are complex.

  • INFORMATION RELATING TO THE FUNDING AGREEMENT Funding Agreement Provider: Hartford Life Insurance Company Funding Agreement: Interest Rate: Contract Payment: $______ Effective Date: ______, 20__ Deposit Amount : $_______ Stated Maturity Date: ______, 20__ (if different from Contract Payment) Day Count Convention: Initial Interest Payment Date: ______, 20__ Special Tax Considerations: None.

  • Purchasing Agent Purchasing Notes as Principal: [ ] Yes [ ] No. If Yes, Purchasing Agent Principal Amount ---------------- ---------------- Total: ________________ Jurisdiction of Organization of the Trust: [Illinois] Additional/Other Terms, if any: __________ Special Tax Considerations, if any: __________ 2.

  • The following is added to the "Special Tax Considerations" provision of the "Death Benefit" section of the Contract: If the Internal Revenue Service determines that the deductions for one or more benefits under this Contract, including, without limitation, any supplemental benefit added by endorsement, are taxable withdrawals, then the Owner may cancel the affected benefit(s) within 90 days after written notice from us.

  • Optional Repayment: [ ] In whole only and not in part [ ] May be in whole or in part Form of trust: [X] Delaware statutory trust [ ] Delaware common law trust Trust Expiration Date: 01/15/2019 Special Tax Considerations: Not Applicable.

  • Subject to the foregoing, under current law and based upon the facts, assumptions and qualifications contained herein, the discussion set forth in the Institutional Prospectus Supplement under the heading "United States Federal Income Tax Considerations" and in the Pricing Supplement under the heading "Special Tax Considerations" to the extent describing matters of United States federal income tax laws or legal conclusions with respect thereto, are my opinions.

  • Optional Repayment: [ ] In whole only and not in part [ ] May be in whole or in part Form of trust: [X] Delaware statutory trust [ ] Delaware common law trust Trust Expiration Date: 01/15/2029 Special Tax Considerations: Not Applicable.

  • Funding Agreement Provider: Hartford Life Insurance Company Interest Rate: Effective Date: ______, 20__ Funding Agreement: Stated Maturity Date: ______, 20__ Day Count Convention: Initial Interest Payment Date: ______, 20__ Special Tax Considerations: None.

  • Option One Mortgage Securities IV LLC Option One Mortgage Services, Inc.

  • Special Tax Considerations for Non-U.S. ShareholdersIn general, non-U.S. Shareholders will be subject to regular federal income tax with respect to their investment in us if the income from the investment is “effectively connected” with the non-U.S. Shareholder’s conduct of a trade or business in the United States.


More Definitions of Special Tax Considerations

Special Tax Considerations. Interest payable on the Notes will be treated as "qualified stated interest" for United States Federal income tax purposes, as it meets the specified criteria referenced in the prospectus supplement under the heading "United States Federal Income Tax Considerations-U.S. Holders-Floating Rate Notes." ANNEX B DELAWARE TRUSTEE SERVICE FEE SCHEDULE As specified in a separate fee agreement. ANNEX C ADMINISTRATOR SERVICE FEE SCHEDULE As specified in a separate fee agreement. ANNEX D DEALER NOTICE INFORMATION AS SPECIFIED IN SCHEDULE 1 TO THE DISTRIBUTION AGREEMENT ATTACHED TO THE SERIES INSTRUMENT AS EXHIBIT E. As specified in a separate fee agreement.
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Special Tax Considerations. Interest payable on the Notes will be treated as "qualified stated interest" for United States Federal income tax purposes, as it meets the specified criteria referenced in the prospectus supplement under the heading "United States Federal Income Tax Considerations-U.S. Holders-Floating Rate Notes."
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Special Tax Considerations. See "Special Tax Considerations" herein
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Special Tax Considerations. There are special tax rules that apply to IRA and other qualified contracts during both the Accumulation Period and Annuity Period governing distributions upon the death of the Owner. These rules are contained in provisions in the attached endorsements and supersede any other distribution rules contained in the Contract. The preceding provisions regarding the death of the Owner are intended to satisfy the distribution at death requirements of section 72(s) of the Internal Revenue Code of 1986, as amended. We reserve the right to amend this Contract by subsequent endorsement as necessary to comply with applicable tax requirements, if any, which are subject to change from time to time. Such additional endorsements, if necessary to comply with amended tax requirements, will be mailed to you and become effective within 30 days of mailing, unless you notify us in writing, within that time frame, that you reject the endorsement.
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Special Tax Considerations. United States Federal Income Taxation The following discussion supplements and, to the extent that it is inconsistent with, replaces the discussion contained in the accompanying Prospectus Supplement in the section entitled "United States Federal Income Tax Considerations". Treatment of the Notes as Contingent Payment Debt Instruments We intend to treat the Notes as subject to the special regulations issued by the U.S. Treasury Department governing contingent payment debt instruments (the "CPDI Regulations"). The remainder of this discussion assumes the Notes will be treated as "contingent payment debt instruments" and subject to the CPDI Regulations. Accrual of Interest on the Notes Pursuant to these regulations, U.S. Holders of the Notes will be required to accrue interest income on the Notes, in the amounts described below, regardless of whether the U.S. Holder uses the cash or accrual method of tax accounting. The CPDI Regulations provide that a U.S. Holder must accrue an amount of ordinary interest income, as original issue discount for United States federal income tax purposes, for each accrual period prior to and including the Stated Maturity Date of the Notes that equals:
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Related to Special Tax Considerations

  • Special Taxes means any and all present or future taxes, levies, imposts, deductions, charges or withholdings, or any liabilities with respect thereto, including those arising after the date hereof as result of the adoption of or any change in law, treaty, rule, regulation, guideline or determination of a Governmental Authority or any change in the interpretation or application thereof by a Governmental Authority but excluding, in the case of Lender, such taxes (including income taxes, franchise taxes and branch profit taxes) as are imposed on or measured by Lender’s net income by the United States of America or any Governmental Authority of the jurisdiction under the laws under which Lender is organized or maintains a lending office.

  • Special Tax means the special tax to be levied in each Fiscal Year on each Assessor’s Parcel of Taxable Property to fund the Special Tax Requirement.

  • Pre-Tax Contributions means, for any Participant, the aggregate of the Participant's Basic Pre-Tax Contributions and Supplemental Pre-Tax Contributions contributed to the applicable Pre-Tax Contribution Account.

  • After-Tax Contributions means amounts withheld from an Employee’s Compensation pursuant to a Salary Reduction Agreement after all applicable state and federal taxes have been deducted. Such amounts are withheld for purposes of purchasing one or more of the Benefit Package Options available under the Plan.

  • 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.

  • 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.

  • Tax Costs which shall mean any and all real estate taxes and other similar charges on real property or improvements, assessments, water and sewer charges, and all other charges assessed, reassessed or levied upon the Project and appurtenances thereto and the parking or other facilities thereof, or the real property thereunder (collectively the "Real Property") or attributable thereto or on the rents, issues, profits or income received or derived therefrom which are assessed, reassessed or levied by the United States, the State of California or any local government authority or agency or any political subdivision thereof, and shall include Landlord's reasonable legal fees, costs and disbursements incurred in connection with proceedings for reduction of Tax Costs or any part thereof; provided, however, if at any time after the date of this Lease the methods of taxation now prevailing shall be altered so that in lieu of or as a supplement to or a substitute for the whole or any part of any Tax Costs, there shall be assessed, reassessed or levied (a) a tax, assessment, reassessment, levy, imposition or charge wholly or partially as a net income, capital or franchise levy or otherwise on the rents, issues, profits or income derived therefrom, or (b) a tax, assessment, reassessment, levy (including but not limited to any municipal, state or federal levy), imposition or charge measured by or based in whole or in part upon the Real Property and imposed upon Landlord, then except to the extent such items are payable by Tenant under Article 6 below, such taxes, assessments, reassessments or levies or the part thereof so measured or based, shall be deemed to be included in the term "Direct Costs." In no event shall Tax Costs included in Direct Costs for any year subsequent to the Base Year be less than the amount of Tax Costs included in Direct Costs for the Base Year. In addition, when calculating Tax Costs for the Base Year, special assessments shall only be deemed included in Tax Costs for the Base Year to the extent that such special assessments are included in Tax Costs for the applicable subsequent calendar year during the Term.

  • Tax Allocations means the allocations set forth in paragraph 4 of Exhibit B.

  • 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).

  • Transaction Payroll Taxes means all employer portion payroll or employment Taxes incurred in connection with any bonuses, option cash-outs or other compensatory payments in connection with the Transactions.

  • Federal Tax Certificate means the Issuer's Federal Tax Certificate dated as of the Issue Date, as the same may be amended or supplemented in accordance with the provisions thereof.

  • Tax Cost means any increase in Tax payments otherwise required to be made to a Taxing Authority (or any reduction in any refund otherwise receivable from any Taxing Authority).

  • U.S. Tax Certificate has the meaning assigned to such term in Section 2.17(f)(ii)(D)(2).

  • 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).

  • 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.

  • 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.

  • U.S. Tax Code means the United States Internal Revenue Code of 1986, as amended.

  • Tax Refunds means refunds of any Cash paid by the Participating CCAA Parties on account of Taxes, refunded to such Participating CCAA Parties from time to time by the applicable Taxing Authorities;

  • Intended Tax Treatment has the meaning set forth in the Recitals.

  • Final Tax Amount has the meaning set forth in Section 4.01(b)(ii).

  • Local taxes means all taxes levied other than taxes levied for school operating purposes.

  • After Tax Amount means the amount of the Aggregate Payments less all federal, state, and local income, excise and employment taxes imposed on the Executive as a result of the Executive’s receipt of the Aggregate Payments. For purposes of determining the After Tax Amount, the Executive shall be deemed to pay federal income taxes at the highest marginal rate of federal income taxation applicable to individuals for the calendar year in which the determination is to be made, and state and local income taxes at the highest marginal rates of individual taxation in each applicable state and locality, net of the maximum reduction in federal income taxes which could be obtained from deduction of such state and local taxes.

  • Allocations means any and all of the allocations described in Sections 1.3(a), 1.3(b), 1.3(c) and 1.3(d) hereof.