Special Tax Event definition

Special Tax Event means that an opinion of a recognized independent tax counsel has been delivered on or after the Issue Date to (i) the Issuer stating that, due to a change in law, ruling or interpretation, the Issuer is, or there is more than an insubstantial risk that the Issuer will be, no longer able to obtain a tax deduction for the purposes of Luxembourg corporation tax for any payment of interest on the Notes and this cannot be avoided by the Issuer taking such reasonable measures as it (acting in good faith) deems appropriate; or(ii) the Guarantor, stating that, due to a change in law, ruling or interpretation, the Guarantor is, or there is more than an insubstantial risk that the Guarantor will be, no longer able to obtain a tax deduction for purposes of Swiss corporation tax for any payment of interest under the Subordinated Guarantee and this cannot be avoided by the Guarantor taking such reasonable measures as it (acting in good faith) deems appropriate.
Sample 1Sample 2
Special Tax Event. ’ means that due to a change in law, ruling or interpretation, the Issuer no longer obtains a tax deduction for the purposes of Swiss corporation tax for any payment of interest by the Issuer on the Loan Notes, and this cannot be avoided by the Issuer taking such reasonable measures as it (acting in good faith) deems appropriate. With respect to the occurrence of a Special Tax Event, the Issuer shall deliver to the Fiscal Agent an opinion of a recognised independent tax counsel which confirms such occurrence.
Sample 1Sample 2Sample 3
Special Tax Event means a sale or transfer of all or part of a Member's Percentage Interest that would cause PAH to recognize any of the "built-in gain" with respect to its interests in the Company or the assets of the Company.
Sample 1Sample 2

Examples of Special Tax Event in a sentence

  • Redemption for Tax Event, Special Tax Event, Regulatory Event, Force Majeure Event or Event of Default:Early Redemption or Monetisation until the Maturity Date Early Redemption Amount : Market ValuePROVISIONS APPLICABLE TO THE UNDERLYING(S) IF ANY24.

  • If the Non-Managing Member does not transfer its interest within such 180 day period, then prior to any transfer which would result in a Special Tax Event, the Non-Managing Member shall again comply with the terms of this subsection 9.2.2.

  • If a Special Tax Event occurs after the Special Provision Effective Date and the Required Lenders (or the Adminstrative Agent on their behalf) given notice to the Borrower, the last proviso in the previous sentence shall be amended accordingly in order to reflect accurately the requirements set forth in, and to accord the applicable Lenders the benefit of, Section 3.01.

  • Redemption for Tax Event, Special Tax Event, RegulatoryEarly Redemption or Monetisation until the Maturity Date Early Redemption Amount : Market Value Event, Force Majeure Event or Event of Default: PROVISIONS APPLICABLE TO THE UNDERLYING(S) IF ANY24.

  • A “Par Redemption Event” means a redemption by the Issuer of the Loan Notes at their principal amount together with any accrued and unpaid interest, if any, and any outstanding Deferred Interest as of the date on which the Loan Notes are redeemed (but excluding such date) at any time after the issue of the Loan Notes, following a Recalculation of Interest Event or a Special Tax Event that is continuing, an Accounting Event, a Ratings Methodology Event or a Regulatory Event.


More Definitions of Special Tax Event

Special Tax Event means an amendment to, or change in, the laws or regulations of any Taxing Jurisdiction affecting taxation, or an amendment to, or change in, an official interpretation or application of such laws or regulations (including, without limitation, pursuant to a final decision or Order of a taxing authority having competent jurisdiction), which amendment or change (a) shall have occurred after November 23, 1999 (or in the case of any jurisdiction that thereafter becomes a Taxing Jurisdiction, as described in Section 22.1, after such jurisdiction becomes a Taxing Jurisdiction) and (b) in the opinion of the Company (which shall be evidenced by an Officer's Certificate and supported by written opinion of counsel having recognized expertise in the field of taxation in the Taxing Jurisdiction, which counsel shall be a firm reasonably satisfactory to the Required Holders and which Officer's Certificate and opinion of counsel shall be delivered to all holders of the Notes prior to any prepayment of Notes under Section 8.7) shall require Additional Payments.
Sample 1
Special Tax Event means a sale or transfer of all or part of a Member's Percentage Interest that would cause Newco to recognize any of the "built-in gain" with respect to its interests in the Company.
Sample 1
Special Tax Event has the meaning specified in the definition of “Excluded Taxes.”
Sample 1
Special Tax Event means that due to a change in law, ruling or interpretation we no longer obtain a tax deduction for the purposes of Swiss corporation tax for any payment of interest on the Loan Notes and this cannot be avoided by us taking such reasonable measures as we (acting in good faith) deem appropriate. With respect to the occurrence of a Special Tax Event, we will deliver to the Fiscal Agent an opinion of a recognized independent tax counsel which confirms such occurrence.
Sample 1
Special Tax Event means a sale or transfer of all or part of a Member's Percentage Interest that would cause Interstate Management to recognize any of the "built-in gain" with respect to its interests in the Company.
Sample 1

Related to Special Tax Event

  • Tax Event means the receipt by the Company and the Trust of an opinion of counsel experienced in such matters to the effect that, as a result of any amendment to or change (including any announced prospective change) in the laws or any regulations thereunder of the United States or any political subdivision or taxing authority thereof or therein, or as a result of any official administrative pronouncement (including any private letter ruling, technical advice memorandum, field service advice, regulatory procedure, notice or announcement, including any notice or announcement of intent to adopt such procedures or regulations) (an “Administrative Action”) or judicial decision interpreting or applying such laws or regulations, regardless of whether such Administrative Action or judicial decision is issued to or in connection with a proceeding involving the Company or the Trust and whether or not subject to review or appeal, which amendment, clarification, change, Administrative Action or decision is enacted, promulgated or announced, in each case on or after the date of original issuance of the Debentures, there is more than an insubstantial risk that: (i) the Trust is, or will be within 90 days of the date of such opinion, subject to United States federal income tax with respect to income received or accrued on the Debentures; (ii) interest payable by the Company on the Debentures is not, or within 90 days of the date of such opinion, will not be, deductible by the Company, in whole or in part, for United States federal income tax purposes; or (iii) the Trust is, or will be within 90 days of the date of such opinion, subject to more than a de minimis amount of other taxes, duties or other governmental charges.

  • Collateral Tax Event means at any time, as a result of the introduction of a new, or any change in, any home jurisdiction or foreign tax statute, treaty, regulation, rule, ruling, practice, procedure or judicial decision or interpretation (whether proposed, temporary or final), interest payments due from the Obligors of any Collateral Debt Obligations in relation to any Due Period becoming properly subject to the imposition of home jurisdiction or foreign withholding tax (other than where such withholding tax is compensated for by a “gross-up” provision in the terms of the Collateral Debt Obligation or such requirement to withhold is eliminated pursuant to a double taxation treaty so that the Issuer as holder thereof is held completely harmless from the full amount of such withholding tax on an after-tax basis) so that the aggregate amount of such withholding tax on all Collateral Debt Obligations in relation to such Due Period is equal to or in excess of 6% of the aggregate interest payments due (for the avoidance of doubt, excluding any additional interest arising as a result of the operation of any gross-up provision) on all Collateral Debt Obligations in relation to such Due Period.

  • Debenture Tax Event" means a "Tax Event" as defined in the Indenture.

  • 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.

  • Tax Event Upon Merger has the meaning specified in Section 5(b).

  • 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.

  • XXXX Event means if there are any Mortgaged Properties at any time, any increase, extension of the maturity or renewal of any of the Commitments or Loans (including any incremental credit facility hereunder, but excluding (i) any continuation or conversion of Borrowings, (ii) the making of any Revolving Loans or (iii) the issuance, renewal or extension of Letters of Credit).

  • Special Tax Requirement means that amount required in any Fiscal Year to: (i) pay debt service on all Outstanding Bonds; (ii) pay periodic costs on the Bonds, including but not limited to, credit enhancement and rebate payments on the Bonds; (iii) pay Administrative Expenses; (iv) pay any amounts required to establish or replenish any reserve funds for all Outstanding Bonds; (v) pay directly for the acquisition or construction of facilities authorized to be financed by IA No. 2 to the extent that inclusion of such amount does not increase the Special Tax levy on Undeveloped Property; and (vi) pay for reasonably anticipated Special Tax delinquencies based on the historical delinquency rate for IA No. 2 as determined by the CFD Administrator; less (vii) a credit for funds available to reduce the annual Special Tax levy, as determined by the CFD Administrator pursuant to the Indenture.

  • Tax Event Repayment Date means the date set out in a notice from the Issuer to the Bondholders pursuant to Clause 10.4 (Early redemption option due to a tax event).

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

  • Change in Tax Classification has the meaning set forth in Section 5.2(h).

  • Tax Event Redemption means, if a Tax Event shall occur and be continuing, the redemption of the Notes, at the option of the Company, in whole but not in part, on not less than 30 days nor more than 60 days' written notice.

  • 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).

  • Maximum Special Tax means the maximum Special Tax, determined in accordance with Section C below, that can be levied in any Fiscal Year on any Assessor’s Parcel.

  • Tax Event Redemption Date means the date upon which a Tax Event Redemption is to occur.

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

  • Annual Special Tax means the Special Tax actually levied in any Fiscal Year on any Assessor’s Parcel.

  • Change in Tax Law means the enactment, promulgation, execution or ratification of, or any change in or amendment to, any law (or in the application or official interpretation of any law) that occurs on or after the date on which the relevant Transaction is entered into.

  • Default Event means an event or circumstance which leads Operator to determine that a Venue User is or appears to be unable or likely to become unable to meet its obligations in respect of an Order or Transaction or to comply with any other obligation under an Agreement or Applicable Law.

  • Special Event means any of a Tax Event, an Investment Company Event or a Capital Treatment Event.

  • ii) Event means any event described in Section 11(a)(ii) hereof.

  • Tax Event Redemption Price means an amount equal to the unpaid principal amount of this Note to be redeemed, which shall be determined by multiplying (1) the Outstanding Principal Amount of this Note by (2) the quotient derived by dividing (A) the outstanding principal amount to be redeemed by Principal Life of the Funding Agreement by (B) the outstanding principal amount of the Funding Agreement.

  • Backup Annual Special Tax means the Special Tax of that name described in Section E.

  • maximum council tax reduction amount means the amount determined in accordance with paragraph 29;

  • Special Events means sports complex events, City of Philadelphia events, weather, and other events that have been or are identified as such by the RTMC.

  • 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.