Subchapter M Transition definition

Subchapter M Transition means, as to a Series, that close of the Series’ books as a partnership for Federal tax purposes having occurred on (or on the day before) the effective date of the Series’ election to be treated as a corporation for Federal tax purposes.
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Subchapter M Transition means the close of the Company’s books as a partnership for Federal tax purposes to occur on (or on the day before) the effective date of the Company’s election to be treated as a corporation for Federal tax purposes.
Sample 1

Examples of Subchapter M Transition in a sentence

  • Xxxxiss xxx xxxxx xersonx xxxxxxxxxxx xxxitted as Members, to become effective upon the effective date of the Company's Subchapter M Transition (as defined herein).

  • Xxxxxxx and those persons hereinafter admitted as Members, to become effective upon the effective date of the Company's Subchapter M Transition (as defined herein).

  • Xxxrixx xxx xxxxx persoxx xxxxxxxxxxx xdmitted as Members, to become effective upon the effective date of the Company's Subchapter M Transition (as defined herein).

Related to Subchapter M Transition

  • Subchapter S Corporation (as defined in the Internal Revenue Code of 1986, as amended), Borrower may pay cash dividends on its stock to its shareholders from time to time in amounts necessary to enable the shareholders to pay income taxes and make estimated income tax payments to satisfy their liabilities under federal and state law which arise solely from their status as Shareholders of a Subchapter S Corporation because of their ownership of shares of stock of Borrower, or (d) purchase or retire any of Borrower's outstanding shares or alter or amend Borrower's capital structure.

  • Section 409A of the Code means the nonqualified deferred compensation rules under Section 409A of the Code and any applicable treasury regulations and other official guidance thereunder.

  • Business Continuity and Disaster Recovery Plan means the Schedule containing plans and provisions for business continuity and disaster recovery.

  • Disregarded Domestic Subsidiary means any direct or indirect (other than through a Foreign Subsidiary) Domestic Subsidiary of which substantially all of its assets consist of Equity Interests of one or more indirect Foreign Subsidiaries.

  • Chapter means a Chapter under this Part;

  • Section 385 Controlled Partnership has the meaning set forth in Treasury Regulation Section 1.385-1(c)(1) for a “controlled partnership”.

  • Payroll Tax Executive Order means the Presidential Memorandum on Deferring Payroll Tax Obligations in Light of the Ongoing COVID-19 Disaster, as issued on August 8, 2020 and including any administrative or other guidance published with respect thereto by any Governmental Authority (including IRS Notice 2020-65).

  • Main Distribution Frame (MDF means the termination frame for outside facility and inter-exchange office equipment at the CO.

  • Taxable REIT Subsidiary means a “taxable REIT subsidiary” within the meaning of Section 856(l) of the Code.

  • Transition Property means the property right created by a financing order, including without

  • United States Tax Compliance Certificate has the meaning specified in Section 3.01.

  • Transition means: 1) the formal and physical process of transferring from school to school or 2) the period of time in which a student moves from one school in the sending state to another school in the receiving state.

  • Separation and Distribution Agreement has the meaning set forth in the Recitals.

  • Tax Regulatory Agreement means the Tax Regulatory Agreement dated as of the date hereof by and among the Company, the Issuer and the Trustee.

  • Section 385 Expanded Group shall have the meaning set forth in Treasury Regulation Section 1.385-1(c)(4) for an “expanded group”.