Tax Distribution Rate shall have the meaning set forth in Section 6(d).
Tax Distribution Rate shall initially mean 45% or such other percentage as may be approved by the Board of Managers from time to time as the approximate highest current marginal combined federal and state income tax rate applicable to an individual resident in Massachusetts (determined after giving effect to the deduction (if allowable) of state income taxes for federal income tax purposes). All amounts
Tax Distribution Rate means such percentage as may be approved by the Board of Managers from time to time as the approximate highest current marginal combined federal and state income tax rate applicable to an individual resident in New York, taking into account the character of the income (such as ordinary income or capital gains) as reasonably determined by the Board of Managers (determined after giving effect to the deduction (if allowable) of state income taxes for federal income tax purposes). All amounts distributed to Members pursuant to this Section 6(d) shall be advances of amounts otherwise distributable to Members under the provisions of Section 6 hereof. Notwithstanding the foregoing, no Tax Distributions shall be made in connection with the liquidation of the LLC or with respect to any proceeds realized by the LLC upon any transaction (other than in the ordinary course of business of the LLC) at the time of or in connection with such liquidation.
Examples of Tax Distribution Rate in a sentence
For purposes of this Section 6(d), the "Tax Distribution Rate" shall initially mean 45% or such other percentage as may be approved by the Board of Managers from time to time as the approximate highest current marginal combined federal and state income tax rate applicable to an individual resident in Massachusetts (determined after giving effect to the deduction (if allowable) of state income taxes for federal income tax purposes).
More Definitions of Tax Distribution Rate
Tax Distribution Rate shall initially mean such percentage as may be approved by the Board of Managers from time to time as the approximate highest current marginal combined United States Federal and state income Tax rate applicable to an individual resident in the State of New York, taking into account the character of the income (such as ordinary income or capital gains) as reasonably determined by the Board of Managers (determined after giving effect to the deduction (if allowable) of state income Taxes for United States Federal income Tax purposes). All amounts distributed to Members pursuant to this Section 6.05 shall be advances of amounts otherwise distributable to Members under the provisions of Sections 6.03 and 6.04 hereof. Notwithstanding the foregoing, no Tax Distributions shall be made in connection with a Liquidation Event or with respect to any proceeds realized by the Company upon any transaction (other than in the ordinary course of business of the Company) at the time of or in connection with such Liquidation Event.
Tax Distribution Rate means thirty-six percent (36%); provided that (i) such thirty-six percent (36%) rate shall be adjusted upward or downward from time to time if the top-bracket U.S. federal income tax rate applicable to ordinary income of corporations (the “Reference Rate”) is changed after the date hereof so that the Tax Distribution Rate shall at all times be equal to one (1) percentage point more than the Reference Rate; and (ii) notwithstanding anything else in this definition, if the activities of the Company shall give rise to state tax liability for the Members in any State of the United States other than California and Texas, the Members shall negotiate in good faith to agree on an appropriate adjustment in respect of such increased tax liability. The Members intend that if the Reference Rate is ever changed such that a blended rate applies to a Member in respect of a taxable year of such Member, the Tax Distribution Rate in respect of such Member for such taxable year shall be equal to one (1) percentage point more than such blended rate. Confidential treatment has been requested for portions of this exhibit. The copy filed herewith omits the information subject to the confidentiality request. Omissions are designated as ****. A complete version of the exhibit has been filed separately with the Securities and Exchange Commission.
Tax Distribution Rate means a Tax rate equal to the maximum combined United States federal and New York City and State income Tax rates applicable to individuals resident in New York City, with such combined rate determined without giving effect to any United States federal deduction for New York City and State Taxes, and without consideration of the effect of any deductions, offsets or credits to such individuals from other sources of income;
Tax Distribution Rate means thirty-six percent (36%); provided that (i) such thirty-six percent (36%) rate shall be adjusted upward or downward from time to time if the top-bracket U.S. federal income tax rate applicable to ordinary income of corporations (the “Reference Rate”) is changed after the date hereof so that the Tax Distribution Rate shall at all times be equal to one (1) percentage point more than the Reference Rate; and (ii) notwithstanding anything else in this definition, if the activities of the Company shall give rise to state tax liability for the Members in any State of the United States other than California and Texas, the Members shall negotiate in good faith to agree on an appropriate adjustment in respect of such increased tax liability. The Members intend that if the Reference Rate is ever changed such that a blended rate applies to a Member in respect of a taxable year of such Member, the Tax Distribution Rate in respect of such Member for such taxable year shall be equal to one (1) percentage point more than such blended rate.
Tax Distribution Rate means the highest marginal combined federal, state and local income tax rate applicable to any of the Members (determined after giving effect to the deduction (if allowable) of state and local income taxes for federal income tax purposes and the deduction for local income taxes (if allowable) for state income tax purposes).
Tax Distribution Rate has the meaning specified in Section 3.1(b)(ii) hereof.
Tax Distribution Rate for any Regular Tax Fiscal Year shall mean the sum of (I) the highest marginal U.S. federal income tax rate (including any surtax) that applies to a U.S. citizen for such Regular Tax Fiscal Year (currently 35%), (II) the Adjusted Applicable Percentage of the highest marginal California personal income tax rate (including any surtax) that applies to a California resident individual for such Regular Tax Fiscal Year (currently scheduled to be 8.033%, which is 77.992% of 10.3%), (III) the Applicable Percentage of the highest marginal California franchise tax rate (including any surtax) that applies to an S corporation doing business in California for such Regular Tax Fiscal Year (currently 0.975%, which is 65% of 1.5%), and (IV) if for such Regular Tax Fiscal Year the U.S. federal self-employment tax applies to Xxxxx Arminak with respect to the passthrough of income to her from HRA as an S corporation, the average tax rate that when multiplied by the product of HRA’s share of the amount determined pursuant to clause (x) of this Section 3.1(b)(ii) above and a fraction the numerator of which is equal to the number of her outstanding shares of the stock of HRA and the denominator of which is equal to the total number of outstanding shares of the stock of HRA (such fraction is currently 19 / 20) yields the amount of such self-employment tax applicable to her for such Regular Tax Fiscal Year with respect to such income (currently zero) multiplied by the excess of 100% over one-half of the percentage determined pursuant to (I) above for such Regular Tax Fiscal Year (currently 1/2 of 35%, or 17.5%, resulting in an excess equal to 82.5%).