Tax Allowance Amount definition
Tax Allowance Amount means, with respect to any Member for any fiscal quarter of the Company, an amount equal to the product of: (a) the highest combined federal, state and local tax rate applicable to any Member (and in the case of any Member that is a “pass-through” entity for income tax purposes, including those applicable to the ultimate beneficial owners of any such Member that are taxable entities or individuals) in respect of the taxable income and taxable loss of the Company in respect of such fiscal quarter, taking into account the deductibility of state and local taxes for federal income tax purposes, and (b) an amount equal to the remainder of (i) such Member’s share of the estimated net taxable income, other than from a Capital Transaction resulting in the liquidation of the Company, allocable to such Member arising from its ownership of an interest in the Company calculated through such fiscal quarter and (ii) any net losses (for income tax purposes) of the Company for prior Fiscal Years or net losses (for income tax purposes) prior fiscal quarters of the then current Fiscal Year that are allocable to such Member that were not previously utilized in the calculation of the Tax Allowance Amounts in a prior Fiscal Year or any prior fiscal quarter of the then current Fiscal Year.
Tax Allowance Amount means, with respect to any Member for any fiscal quarter of the Company, an amount equal to the product of: (i) the highest combined federal and applicable state and local tax rate applicable to any Member in respect of the taxable income and taxable loss of the Company in respect of such fiscal quarter, taking into account the deductibility of state and local taxes for federal income tax purposes, times (ii) an amount equal to the remainder of (a) such Member’s share of the estimated net taxable income allocable to such Member arising from its ownership of an interest in the Company calculated through such fiscal quarter minus (b) the sum of (1) any net losses (for income tax purposes) of the Company for prior Fiscal Years and such fiscal quarter that are allocable to such Member that were not previously utilized in the calculation of the Tax Allowance Amounts in a prior Fiscal Year and (2) the amount of all prior distributions (including distributions of Tax Allowance Amounts) for such Fiscal Year, all as determined by the Managing Member.
Tax Allowance Amount means cash distributions to each Member, proportionately based on each Member’s Percentage Interest, (i) with respect to each applicable calendar quarter, until each Member receives a distribution equal to the product obtained by multiplying (x) the sum (if greater than zero) of the items of taxable income, gain, loss, and deduction of the Company expected to be allocated to such Member under Article V for such calendar quarter by (y) the Assumed Tax Rate; and (ii) after the end of any taxable year, until each Member receives a distribution equal to the excess of (A) the product obtained by multiplying (x) the sum (if greater than zero) of the items of taxable income, gain, loss, and deduction of the Company allocated to such Member under Article V for such taxable year by (y) the Assumed Tax Rate, over (B) quarterly distributions previously made to such Member pursuant to clause (i) above with respect to such taxable year.
Examples of Tax Allowance Amount in a sentence
Upon such determination, the Company shall distribute each Member’s Tax Allowance Amount to such Member.
For the purposes of computing the Tax Allowance Amount, if any, the effect of any benefit to a Member under Section 734 or 743 of the Code, if any, will be ignored.
A Tax Allowance Amount paid to a Member under this Section 5.10 shall be treated as an advance against distributions to the same Member under this Agreement.
Notwithstanding Section 3.03 hereof, on or before the date that estimated income taxes are required to be paid, the Managing Member shall determine the Tax Allowance Amount for each Member in respect of such quarter.
Upon such determination, and to the extent that the Company has not made minimum distributions to each Member in an amount (in cash or property) at least equal to such Member’s respective Tax Allowance Amount for the then current fiscal quarter, the Company shall distribute to each member an amount so that after such distribution is made each Member shall have received minimum aggregate distributions for such fiscal quarter equal to each such Member’s Tax Allowance Amount.
More Definitions of Tax Allowance Amount
Tax Allowance Amount means, with respect to any Limited Partner for any fiscal quarter of the Partnership, an amount equal to the product of: (i) the highest combined federal and applicable state and local tax rate applicable to any Limited Partner in respect of the taxable income and taxable loss of the Partnership in respect of such fiscal quarter, taking into account the deductibility of state and local taxes for federal income tax purposes, times (ii) an amount equal to the remainder of (a) such Limited Partner’s share of the estimated net taxable income allocable to such Limited Partner arising from its ownership of an interest in the Partnership calculated through such fiscal quarter minus (b) the sum of (1) any net losses (for income tax purposes) of the Partnership for prior Fiscal Years and such fiscal quarter that are allocable to such Limited Partner that were not previously utilized in the calculation of the Tax Allowance Amounts in a prior Fiscal Year and (2) the amount of all prior Distributions for such Fiscal Year, all as determined by the General Partner.
Tax Allowance Amount means, with respect to any Partner, for any calendar quarter, (i) 40% of the excess of (a) the estimated taxable income allocable to such Partner arising from its ownership of a partnership interest in the Partnership for the fiscal year through such calendar quarter over (b) any losses of the Partnership for prior fiscal years and such fiscal year that are allocable to such Partner that were not previously utilized in the calculation of Tax Allowance Amounts minus (ii) prior distributions of Tax Allowance Amounts for such fiscal year, all as determined by the General Partner in good faith.
Tax Allowance Amount means, with respect to any Member, for any calendar quarter, (i) forty percent (40%) of the excess of (a) the estimated taxable income allocable to such Member arising from its ownership of an interest in BMC for the fiscal year through such calendar quarter over (b) any losses of BMC for prior fiscal years and such fiscal year that are allocable to such Member that were not previously utilized in the calculation of Tax Allowance Amounts for any period minus (ii) prior distributions of Tax Allowance Amounts for such fiscal year, all as determined by the Accountants in good faith. The amount so determined by the Accountants shall be the Tax Allowance Amount for such period and shall be final and binding on all Members.
Tax Allowance Amount means, with respect to any partner of RAS (including a warrant holder if such warrant holder is treated as owning an equity interest in RAS for U.S. federal, state or local income tax purposes), for any calendar quarter, (i) forty percent (40%) of the excess of (a) the estimated taxable income allocable to such partner of RAS arising from its ownership of a partnership interest in RAS for the fiscal year through such calendar quarter over (b) any losses of RAS for prior fiscal years and such fiscal year that are allocable to such partner of RAS that were not previously utilized in the calculation of Tax Allowance Amounts minus (ii) prior distributions of Tax Allowance Amounts for such fiscal year, all as determined by the general partner of RAS in good faith. The amount so determined by the general partner of RAS shall be the Tax Allowance Amount for such period and shall be final and binding on all partners of RAS.
Tax Allowance Amount means, for any calendar quarter, an amount of cash equal to the product of (i) the aggregate amount of net taxable income
Tax Allowance Amount means, with respect to any Member, for any calendar quarter (i) forty-five percent (45%) of the excess of (a) such Member’s share of the estimated net taxable income allocable to such Member arising from its ownership of an interest in the Company calculated through such calendar quarter over (b) any net losses (for income tax purposes) of the Company for prior Fiscal Years and such Fiscal Year that are allocable to such Member that were not previously utilized in the calculation of the Tax Allowance Amounts in a prior Fiscal Year minus (ii) all prior distributions (including distributions of Tax Allowance Amounts) for such Fiscal Year, all as determined by the Board of Managers in good faith. The amount so determined by the Board of Managers shall be the Tax Allowance Amount for such period and shall be final and binding on all Members.
Tax Allowance Amount means, with respect to any Member, 40% (which percentage the Management Committee may from time to time hereafter, upon the unanimous vote of the Managers, adjust to reflect material changes in tax rates) of the greater of (A) such Member’s share of the estimated net taxable income allocable to such Member arising from its ownership of an interest in the Company or (B) such Member’s share of Net Profits, in either case, after subtracting from (A) or (B), as the case may be, the Company’s equity in the earnings of First Advantage and after subtracting the net profits of CoreLogic (to the extent otherwise included in net taxable income or Net Profits, as the case may be), plus any dividends paid by First Advantage and CoreLogic to the Company, in each case for the period for which such payment of taxes is being made.