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.

• 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.

• Except as provided in Section 3.3(b), LENSAR shall prepare any Pre-Distribution Period or Straddle Period LENSAR Separate Return in accordance with Past Practices (unless the Parties jointly determine that there is not at least Substantial Authority for the use of such Past Practices, and to the extent any items, methods or positions are not covered by Past Practices), then LENSAR shall prepare such Tax Return in accordance with reasonable Tax accounting practices selected by LENSAR.

• 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).

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

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 described in Section 6662 of the Code, provided that if state, local or foreign Tax law is at issue, Substantial Authority shall continue to have the same meaning, but whether Substantial Authority exists shall be determined in light of relevant state, local or foreign precedent.