Substantial Authority definition

Substantial Authority means the weight of authorities for the tax treatment of an item is substantial in relation to the weight of authorities supporting contrary positions.

Substantial Authority has the meaning set forth in Section 3.4(c) of this Agreement.

Substantial Authority means substantial authority within the meaning of Section 6662(d)(2)(B)(i) of the Code and the Treasury Regulations promulgated thereunder.

Examples of Substantial Authority in a sentence

• Such treatment reported on any Tax Return for which Cyclerion is the Responsible Party shall be consistent with that on any Tax Return filed or to be filed by Ironwood or any member of the Ironwood Group or caused or to be caused to be filed by Ironwood, unless the Parties jointly determine that there is not Substantial Authority for such Tax treatment.

• Such treatment reported on any Tax Return for which 2seventy is the Responsible Party shall be consistent with that on any Tax Return filed or to be filed by bluebird or any member of the bluebird Group or caused to be filed by bluebird, unless the Parties jointly determine that there is not Substantial Authority for such Tax treatment.

• The Lenders shall use commercially reasonable efforts to deliver to the Company and the applicable Borrower a Substantial Authority Recast Opinion with respect to the Cash Loan made to such Borrower at the time such Cash Loan is made (which opinion, for the avoidance of doubt, shall be obtained at the expense of the Lenders).

• For this purpose, the Tax treatment shall be determined by ConocoPhillips and shall be agreed to by Xxxxxxxx 66 unless either (i) no Substantial Authority exists for the technical merits of the position, or (ii) such Tax treatment is inconsistent with the Tax treatment contemplated in the Ruling Requests, the Tax Opinions/Rulings and/or the ConocoPhillips Group Transaction Returns.

• Xxxxxxxx 66 shall use reasonable best efforts to respond in writing to ConocoPhillips with any comments no later than the date on which ConocoPhillips files such Tax Return with the applicable Tax Authority, provided, however that Xxxxxxxx 66’s comments shall be limited to the reporting of any material Tax Item on such Tax Return with respect to which Xxxxxxxx 66 reasonably believes that no Substantial Authority exists for the technical merits of the position.

More Definitions of Substantial Authority

Substantial Authority as defined in Section 2.1.

Substantial Authority has the meaning provided in the Treasury Regulations under section 6662 of the Code.

Substantial Authority. For Federal income tax purposes, has the meaning applicable for purposes of Section 6662 of the Code and relevant Treasury regulations.

Substantial Authority means, in addition to any definition of substantial authority incorporated by subsection (j), that the following authority supports the tax treatment of an item:

Substantial Authority shall have the meaning assigned to such term in Section 6662(d)(2)(B) of the Code and Treas. Reg. § 1.6662-4(d) or any successor provisions that set forth the standard to avoid the incurrence of accuracy-related penalties under the Code;

Substantial Authority means “substantial authority” within the meaning of Section 6662(d)(2)(B) of the Code and Treasury Regulations Section 1.6662-4(d) (or, in the case of any Taxes not subject to Section 6662(a), an analogous standard).

Substantial Authority shall have the meaning set forth in Section 3.3(a).