Substantial Economic Effect definition

Substantial Economic Effect. Requirement. Federal tax law permits the members to agree on how the income of the entity will be allocated among them, but requires that this allocation reflect the economic reality of their business arrangement, as tested under complicated rules (i.e. the “substantial economic effect” test under Treasury regulations 1.704-1(b)). Generally, for an allocation to have economic effect, it must be consistent with the underlying economic arrangement of the partners. The partner must bear the economic benefit, or burden, of the allocation. 8 Local counsel to confirm that this complies with local law. TBD whether a different measure of patronage is appropriate. directed, by the Board, to pay an assessment to cover the loss (resulting in a reduction in current tax liability) or the loss will be carried back or forward. The distribution percentages referred to in this section can be changed for a coming Fiscal Year by the Members.

Examples of Substantial Economic Effect in a sentence

  • Substantial Economic Effect.......................................................

  • China • Received China NMPA17 NDA approval for ORPATHYS® (savolitinib) as a treatment for patients with MET18 exon 14 skipping alteration NSCLC19 in June 2021, making savolitinib the first-in-class selective MET inhibitor in China; and• Received second China NMPA NDA approval for SULANDA® in June 2021 as a treatment for patients with advanced pancreatic NET.

  • Marich, Substantial Economic Effect and the Value Equals Basis Conundrum, 42 Tax L.

  • It examines the relationship between the regulatory anti-abuse rules, the Substantial Economic Effect (“SEE”) safe harbor, and the section 704(c) doctrine, while revealing their imperfections.

  • Substantial Economic Effect...........................................................

  • Marich, Substantial Economic Effect and the Value Equals Basis Conundrum,42 Tax L.

  • Substantial Economic Effect.......................................

Related to Substantial Economic Effect

  • Special Economic Zone means each Special Economic Zone notified under the proviso to sub-section (4) of section 3 and sub-section (1) of section 4 (including Free Trade and Warehousing Zone) and includes an existing Special Economic Zone;

  • Stochastic effect means a health effect that occurs randomly and for which the probability of the effect occurring, rather than its severity, is assumed to be a linear function of dose without threshold. Hereditary effects and cancer incidence are examples of stochastic effects. For purposes of these rules, “probabilistic effect” is an equivalent term.

  • freezing of economic resources means preventing the use of economic resources to obtain funds, goods or services in any way, including, but not limited to, by selling, hiring or mortgaging them;

  • Regional economic integration organization means an organization constituted by sovereign States of a given region to which its member States have transferred competence in respect of matters governed by this Convention and which has been duly authorized, in accordance with its internal procedures, to sign, ratify, accept, approve or accede to this Convention;

  • Nonstochastic effect means a health effect, the severity of which varies with the dose and for which a threshold is believed to exist. Radiation-induced cataract formation is an example of a nonstochastic effect. For purposes of these regulations, "deterministic effect" is an equivalent term.

  • exclusive economic zone ’ means the zone established by Presidential Proclamation Numbered 5030, dated March 10, 1983, including the ocean waters of the areas referred to as ‘‘eastern special areas’’ in Article 3(1) of the Agreement between the United States of America and the Union of Soviet Socialist Re- publics on the Maritime Boundary, signed June 1, 1990;

  • Capital Accounts An individual capital account shall be maintained for each Partner, and capital contributions to the Partnership by the Partners shall be credited to such accounts. Partnership profits or losses shall also be charged or credited to the separate capital accounts in the manner provided in this Agreement. No interest shall be paid on the capital account of any Partner.

  • Net Economic Return shall have the meaning ascribed to such term in paragraph 2 of Exhibit E to the Lease.

  • Greatest economic need means the need resulting from an annual income level at or below the official poverty guideline as defined in IAPI issued by the department.

  • Capital Account Limitation has the meaning provided in Section 4.5(b) hereof.

  • OP Unit Economic Balance has the meaning set forth in Section 6.03(c) hereof.

  • Partnership Minimum Gain has the meaning set forth in Regulations Section 1.704-2(b)(2), and the amount of Partnership Minimum Gain, as well as any net increase or decrease in Partnership Minimum Gain, for a Partnership Year shall be determined in accordance with the rules of Regulations Section 1.704-2(d).

  • Broad-Based Black Economic Empowerment Act means the Broad-Based Black Economic Empowerment Act, 2003 (Act No. 53 of 2003);

  • Net Loss means, for each fiscal year or other applicable period, an amount equal to the Partnership’s taxable income or loss for such year or period as determined for federal income tax purposes by the General Partner, determined in accordance with Section 703(a) of the Code (for this purpose, all items of income, gain, loss or deduction required to be stated separately pursuant to Section 703(a) of the Code shall be included in taxable income or loss), adjusted as follows:

  • Capital Account means, with respect to any Partner, the Capital Account maintained for such Partner in accordance with the following provisions:

  • 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.

  • Safe haven means a readily recognizable and readily accessible site at which security is present or from which, in the event of an emergency, the transport crew can notify and wait for the local law enforcement authorities.

  • Partnership Unit Economic Balance means (i) the Capital Account balance of the General Partner plus the amount of the General Partner’s share of any Partner Minimum Gain or Partnership Minimum Gain, in each case to the extent attributable to the General Partner’s Partnership Units divided by (ii) the number of the General Partner’s Partnership Units.

  • Gain means a gain of any property, whether temporary or permanent, and includes the keeping by a person of any property that he or she already has;

  • Economic Minimum means the lowest incremental MW output level, submitted to PJM market systems by a Market Participant, that a unit can achieve while following economic dispatch.

  • Regulatory Allocations shall have the meaning set forth in Section 6.3.A(viii).

  • Common Unit Economic Balance means (i) the Capital Account balance of the General Partner, plus the amount of the General Partner’s share of any Partner Minimum Gain or Partnership Minimum Gain, in either case to the extent attributable to the General Partner’s ownership of Partnership Common Units and computed on a hypothetical basis after taking into account all allocations through the date on which any allocation is made under Section 6.2.D hereof, divided by (ii) the number of the General Partner’s Partnership Common Units.

  • Broad-Based Black Economic Empower-ment Act means the Broad-Based Black Economic Empowerment Act, 2003 (Act No. 53 of 2003);

  • Economic Capital Account Balances has the meaning set forth in Section 6.1.E.

  • Target Capital Account means the Capital Account of a Member as of the end of each fiscal year, increased by any amount that such Member is obligated to restore under this Agreement, is treated as obligated to restore under Treasury Regulations Section 1.704-1(b)(2)(ii)(c), or is deemed obligated to restore under the penultimate sentences of Treasury Regulations Section 1.704-2(g)(1) and (i)(5).

  • CM/ECF means the Bankruptcy Court’s Case Management and Electronic Case Filing system.