Tax Exempt Partner means any Limited Partner which is exempt from income taxation under ss.501(a) of the Code.
Tax Exempt Partner means any equityholder of a Shareholder (or, with respect to any equityholder of a Shareholder that is taxed as a partnership for federal income tax purposes (a "flow-through entity"), any equityholder of such flow-through entity) which is exempt from income taxation under § 501(a) of the Code.
Tax Exempt Partner means any (a) direct partner, member or owner of Series A Preferred Units or (b) indirect partner, member, or owner of Series A Preferred Units holding such Units through one or more partnerships or other pass-through entities that is, in either case, a “tax-exempt entity” (unless such Person would be subject to tax under Code Section 511 on all income from the Partnership) or “tax-exempt controlled entity” (unless with respect to a “tax-exempt controlled entity,” an election is made under Code Section 168(h)(6)(F)(ii)) as those terms are defined in Code Section 168(h).
Examples of Tax Exempt Partner in a sentence
A Direct Investment Tax Exempt Partner181 Initials of Electing Tax Exempt Partner: Direct Investment Tax Exempt Partners.
Please indicate below whether the Investor wishes to elect to be an Electing Tax Exempt Partner or a Direct Investment Tax Exempt Partner with respect to all UBTI Investments.
As provided in the Partnership Agreement, an Electing Tax Exempt Partner will participate in a UBTI Partnership indirectly through one or more Corporations, such that any proceeds to the Electing Tax Exempt Partner will be net of any taxes and other expenses paid or payable by such Corporations.
More Definitions of Tax Exempt Partner
Tax Exempt Partner means, with respect to any determination hereunder, any Limited Partner that is (or any Limited Partner that is a flow-through entity for U.S. federal income tax purposes that has a partner or member that is) exempt from U.S. federal income taxation under Code §501(a) or, as determined by the General Partner in its sole discretion from time to time, other Code sections.
Tax Exempt Partner means a partner exempt from Virginia income taxation. If such partner has unrelated business taxable income but otherwise is exempt from Virginia income taxation, such partner shall be considered a “tax-exempt partner.” "Unrelated business taxable income" has the same meaning as such term is defined in IRC § 512.
Tax Exempt Partner means a Limited Partner that is exempt from United States federal income tax or a limited partnership or other entity taxed as a partnership or disregarded for United States income tax purposes that has one or more limited partners or equity owners that are exempt from United States federal income tax, and that in each case so indicates on its Investor Questionnaire. The General Partner shall use its reasonable best efforts to ensure that the Partnership shall not enter into any transaction, not otherwise exempt, that would constitute participation by the Partnership or any Limited Partner in a “prohibited transaction” as defined in Section 4975 of the Code. With respect to any investments in, or acquisition of the Securities of or other interests in, a partnership or other unincorporated entity, the General Partner shall be deemed to have complied with this Section
Tax Exempt Partner means a Limited Partner that is exempt from United States federal income tax or a limited partnership or other entity taxed as a partnership for United States income tax purposes that has one or more limited partners or equity owners that are exempt from United States federal income tax, and that in each case so indicates on its Investor Questionnaire. The General Partner shall use its reasonable best efforts to ensure that the Partnership shall not enter into any transaction, not otherwise exempt, that would constitute participation by the Partnership or any Limited Partner in a “prohibited transaction” as defined in Section 4975 of the Code. With respect to any investments in, or acquisition of the Securities of or other interests in, a partnership or other unincorporated entity, the General Partner shall be deemed to have complied with this Section 10.16 if the partnership agreement or other applicable documents of such entity contain provisions regarding unrelated business taxable income offering the limited partners substantially the same protection as offered by this Section 10.16. Notwithstanding the foregoing, the General Partner shall be under no obligation to avoid the recognition of unrelated taxable business income by any Tax-Exempt Partner to the extent that such recognition is attributable to the operation of a management fee offset hereunder. In no event shall the General Partner (or any other person) be liable for monetary damages resulting from or arising out of its breach of this Section 10.16 unless such breach is the result of willful disregard by the General Partner of the provisions of this Section 10.16.
Tax Exempt Partner means a Partner that is a plan described in Section 401(a) of the Code that is exempt from U.S. federal income tax under Section 501(a) of the Code, any other organization described in Section 511(a)(2) of the Code, a trust described in Section 664 of the Code, or an account that is described in Section 408 of the Code.
Tax Exempt Partner means (a) a Limited Partner who purchases Units from the Partnership during the offering period and who at the time of such purchase is (i) a Qualified Plan, (ii) an organization (other than a cooperative described in Section 521 of the Code) which is exempt from tax imposed by Chapter 1 (Normal Taxes and Surtaxes) of the Code, or (iii) a foreign person or entity, unless more than 50% of the gross income derived by the foreign person or entity from the Partnership is subject to U.S. income tax, and (b) each subsequent transferee of any of such Units.
Tax Exempt Partner means any Limited Partner (or any partner or member of a Limited Partner that is a flow through entity for federal income tax purposes) which is exempt from income taxation under §501(a) of the Code.