Tax Equity Arrangement definition

Tax Equity Arrangement means an investment structure or arrangement involving one or more investors seeking a target internal rate of return that includes federal income tax credits and/or tax depreciation (each, a “Tax Equity Investor”) and generally (i) described in Revenue Procedures 2001-28 (sale leaseback (with or without “leverage”)), 2007-65 (flip partnership) or 2014-12 (flip partnership and master tenant partnership) as those revenue procedures are reasonably applied or analogized to a solar project transaction (as opposed to a wind farm or rehabilitated real estate project) or (ii) contemplated by Section 50(d)(5) of the Code (a pass- through/inverted lease).
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Tax Equity Arrangement means an investment structure or arrangement involving one or more investors seeking a target internal rate of return that includes federal income tax credits and/or tax depreciation (each, a “Tax Equity Investor”) and generally (i) described in Revenue 36 NTD: Insert “ninety” and “90” as appropriate (unless there is an uneven distribution of Delay Liquidated Damages after the Guaranteed Substantial Completion Date). Procedures 2001-28 (sale leaseback (with or without “leverage”)), 2007-65 (flip partnership) or 2014-12 (flip partnership and master tenant partnership) as those revenue procedures are reasonably applied or analogized to a solar project transaction (as opposed to a wind farm or rehabilitated real estate project) or (ii) contemplated by Section 50(d)(5) of the Code (a pass- through/inverted lease).
Sample 1
Tax Equity Arrangement means an investment structure or arrangement involving one or more investors seeking a target internal rate of return that includes federal income tax credits and/or tax depreciation (each, a “Tax Equity Investor”) and generally (i) described in Revenue Procedures 2001-28 (sale leaseback (with or without “leverage”)), 2007-65 (flip partnership) or 2014-12 (flip partnership and master tenant partnership) as those revenue procedures are
Sample 1

Examples of Tax Equity Arrangement in a sentence

  • Neither the Borrower nor any Subsidiary is party to any tax sharing agreement with any Person or any other agreement pursuant to which it is liable for the material Taxes of another Person (including with any Affiliate of the Borrower or its Subsidiaries) other than in connection with a Permitted Tax Equity Arrangement or customary provisions contained in any agreements entered into in the ordinary course of business and not primarily related to Taxes.

  • Borrower shall have furnished to the Independent Engineer each then current financial model prepared by or on behalf of Borrower or any of its Subsidiaries in connection with such Project, including any such model prepared in connection with any Permitted Tax Equity Arrangement for such Project, to the extent that the inputs and revenue, technical, operating or construction assumptions from any such model are incorporated into the Base Case Model delivered pursuant to the foregoing clause (i).

  • In the event that Buyer secures a Tax Equity Arrangement for the Transactions, FERC and other regulatory approvals may be included as Buyer’s Regulatory Approvals and additional language added to the Agreement to address such approvals.

  • Each Obligor and each of its Subsidiaries is a partnership or an entity disregarded as separate from its owner for U.S. federal income tax purposes (other than Persons (other than the Borrower) with different Tax status in connection with a Permitted Tax Equity Arrangement, Tax Equity Document or Facility Acquisition, provided that in each case the expected tax effects of such other Tax status are properly reflected in the applicable Pro Forma Model).

Related to Tax Equity Arrangement

  • Access Arrangement means an arrangement for access to a Covered Pipeline that has been approved by the Relevant Regulator.

  • Tax Sharing Arrangement means any written or unwritten agreement or arrangement for the allocation or payment of Tax liabilities or payment for Tax benefits with respect to a consolidated, combined or unitary Tax Return which includes the Company.

  • Compensation Arrangement means any direct or indirect compensatory payment or other financial agreement, arrangement or understanding with any person or entity other than the Corporation, including any agreement, arrangement or understanding with respect to any direct or indirect compensation, reimbursement or indemnification in connection with candidacy, nomination, service or action as a nominee or as a director of the Corporation;

  • legal arrangement means a trust or other similar arrangement;

  • Foreign Benefit Arrangement means any employee benefit arrangement mandated by non-U.S. law that is maintained or contributed to by any Credit Party or any of its Subsidiaries.

  • Benefit Arrangement means at any time an employee benefit plan within the meaning of Section 3(3) of ERISA which is not a Plan or a Multiemployer Plan and which is maintained or otherwise contributed to by any member of the ERISA Group.

  • referral arrangement means any arrangement in which a registrant agrees to pay or receive a referral fee;

  • Multiple employer welfare arrangement means a multiple employer welfare arrangement

  • Share Compensation Arrangement means any stock option, stock option plan, employee stock purchase plan or any other compensation or incentive mechanism involving the issuance or potential issuance of Shares, including a share purchase from treasury which is financially assisted by the Corporation by way of a loan, guarantee or otherwise;

  • Non-Exempt Severance Arrangement means a severance arrangement or other agreement between the Participant and the Company that provides for acceleration of vesting of an Award and issuance of the shares in respect of such Award upon the Participant’s termination of employment or separation from service (as such term is defined in Section 409A(a)(2)(A)(i) of the Code (and without regard to any alternative definition thereunder) (“Separation from Service”) and such severance benefit does not satisfy the requirements for an exemption from application of Section 409A provided under Treasury Regulations Section 1.409A-1(b)(4), 1.409A-1(b)(9) or otherwise.

  • Group health benefit plan means any health care plan, subscription contract, evidence of

  • Change in Control Agreement means a written Change in Control Agreement between an employee and the Company or an Affiliate.

  • Travel Arrangements means: (a) transportation: (b) accommodations: and (c) other specified services arranged by the Travel Supplier for the covered trip.

  • Payroll Tax Executive Order means the Presidential Memorandum on Deferring Payroll Tax Obligations in Light of the Ongoing COVID-19 Disaster, as issued on August 8, 2020 and including any administrative or other guidance published with respect thereto by any Governmental Authority (including IRS Notice 2020-65).

  • Employee Benefits Agreement means the Employee Benefits Agreement by and between Parent and SpinCo, which agreement shall be entered into prior to or on the Distribution Date in the form attached hereto as Exhibit A.

  • Life-of-the-unit, firm power contractual arrangement means a unit participation power sales agreement under which a utility or industrial customer reserves, or is entitled to receive, a specified amount or percentage of nameplate capacity and associated energy from any specified unit and pays its proportional amount of such unit's total costs, pursuant to a contract:

  • Severance Plan means any severance plan maintained by the Company that is applicable to the Participant.

  • Employee Matters Agreement means the Employee Matters Agreement to be entered into by and between Parent and SpinCo or the members of their respective Groups in connection with the Separation, the Distribution or the other transactions contemplated by this Agreement, as it may be amended from time to time.

  • CIC Severance Plan means the Company’s Change in Control Severance Plan, as may be amended from time to time, or any successor plan, program or arrangement thereto.

  • Health benefits plan means a benefits plan which pays or

  • Tax Protection Agreement means, collectively, (a) that certain Tax Protection Agreement, dated as of October 7, 2013 among the Parent, the Borrower, and the other parties named therein and (b) that certain Stockholders Agreement, dated as of August 23, 2016 among Parent and Q REIT Holding LLC, and the other parties named therein (and specifically, the tax related provisions in Article 6 thereof).

  • Transaction Payroll Taxes means all employer portion payroll or employment Taxes incurred in connection with any bonuses, option cash-outs or other compensatory payments in connection with the Transactions.

  • Continuing care retirement community means a residential

  • Arrangement Agreement has the meaning ascribed thereto in the recitals hereof;

  • Pension Benefits Act means The Pension Benefits Act of Ontario and regulations thereunder as amended from time to time.

  • Project labor agreement means a form of pre-hire collective