Tax Partnerships definition

Tax Partnerships means the partnerships created and existing for federal income and Texas franchise tax purposes pursuant to the Operating Agreements (including any exhibits attached thereto).
Tax Partnerships means any Acquired Company treated as a partnership for federal income tax purposes and listed on Section 1.03 of the Seller Disclosure Schedules. “Tax Returns” means any return, report, information return or other document (including schedules or any related or supporting information) filed or required to be filed with any Governmental Authority in connection with the determination, assessment or collection of any Tax or the administration of any Laws relating to any Tax. “Termination Date” has the meaning set forth in Section 9.01(b). “TGCM” means True Green Capital Management LLC, a Delaware limited liability company. “Threshold Amount” has the meaning set forth in Section 6.17(e)(i). “Transaction Documents” means this Agreement, the Assignment Agreement (Company), the Assignment Agreement (TGC III FiT LA, LLC) (solely in the case of a Development Stage Incompletion), the Assignment Agreement (USPS LA Solar Holdings, LLC)

Examples of Tax Partnerships in a sentence

  • All such items shall be taken into account in computing the Tax Partnership's basis, depreciation, depletion, gross income, deductible expenses, and/or gain or loss, as appropriate, and shall be allocated among the Parties in accordance with Article III hereof.

  • All such items shall be taken into account in computing the Tax Partnership's gross income and gain or loss, as appropriate, and shall be allocated among the Parties in accordance with Article III hereof.

  • Any Simulated Loss shall be allocated to the Parties and shall reduce their respective Capital Accounts in the same percentages as the costs of the property sold were allocated up to an amount equal to each Party's share of the Tax Partnership's Simulated Basis in such property at the time of such sale.

  • The Company and its Subsidiaries have no interest in any partnerships other than Tax Partnerships and the partnerships identified in Exhibit E.

  • Other than the Tax Partnerships, there are no assets held by any Company or Tax Partnership that are treated as an entity for U.S. federal income tax purposes.

  • So long as this Note is outstanding, Borrower shall not, and Borrower shall not permit any of its subsidiaries to, directly or indirectly, incur or guarantee, assume or suffer to exist any Indebtedness that would rank senior or pari passu to the Note, other than the Senior Debt, Indebtedness existing on the date hereof and Permitted Indebtedness.

  • To the extent permitted under applicable Law, all Tax Returns with respect to Tax periods that include the Closing Date will be prepared and filed on the basis that the applicable Tax period of the Companies and the Tax Partnerships ended on the Closing Date Date.

  • Plant fuel, flared gas and other uses or losses incident to processing: The volume of gas which is attributable to such uses or losses shall be as determined by the measurement with meters of each such use occurring in the Plant as may be necessary to determine accurately the total volume of gas so used, such meters to be installed and operated as mutually agreed by Plant Owners and Southern.

  • The Income Taxes attributable to a Purchased Entity's direct and indirect interest in any Tax Partnerships shall be determined by a closing of the books of each Tax Partnership as of the end of the Closing Date, and all Income Taxes attributable to the operations and activities of a Tax Partnership through the end of the Closing Date using the accrual accounting method shall be considered Income Taxes of the Purchased Entity allocable to a Pre-Closing Period.

  • The Taxes attributable to the Companies' direct and indirect interest in the Tax Partnerships shall be determined by a closing of the books of each Tax Partnership as of the end of the day on April 1, 1998, and all Taxes attributable to the operations and activities of a Tax Partnership through the end of the day on April 1, 1998 shall be considered Taxes of the Companies allocable to a Pre-Signing Period.


More Definitions of Tax Partnerships

Tax Partnerships means (a) the Foreland Tax Partnership, (b) the MWP Tax Partnership, (c) the Xxxxxxxx Tax Partnership, and (d) the Molopo Tax Partnership.
Tax Partnerships means Netlink USA, SNG, UVI Network WGN, Superstar Entertainment Netlink WGN and any other entity treated as a partnership for federal income tax purposes in which the Companies have a direct or indirect interest. Non-Return Taxes shall be apportioned based upon the number of days covered by such payment which are on or before April 1, 1998 and the total number of days covered by such payment, in each case, to the extent such amount exceeds any amount previously paid to Purchaser with respect to such Tax pursuant to Section 9.3 or 9.5, as applicable. Seller shall pay such amounts as it is obligated to pay to Purchaser within 10 calendar days after payment of any applicable Tax liability by Purchaser or any subsidiary of Purchaser and to the extent not paid by Seller within such 10-day period, the amount due shall thereafter include interest thereon at a rate per annum equal to the "overpayment rate" under Section 6621(a) of the Code (the "Overpayment Rate"), adjusted as and when changes to such Overpayment Rate shall occur, compounded semi-annually. Seller shall indemnify and hold harmless Purchaser or any subsidiary of Purchaser, successors and assigns, from and against (i) any Tax liability for periods prior to and including the Closing Date resulting solely from the Netlink Subsidiaries being severally liable for any Taxes of any consolidated group of which the Netlink Corporations is or was a member pursuant to Treasury Regulations (S) 1.1502-6 or any analogous state or local tax provision (including, without limitation, any Tax liability with respect to any Pre-Closing Consolidated Return), and (ii) any Tax liability resulting from the Netlink Corporations ceasing to be a member of any Selling Affiliated Group filing consolidated or combined Tax Returns (including, without limitation, Tax liability for excess loss accounts and deferred intercompany gains).

Related to Tax Partnerships

  • Partnerships is defined in the Recitals of this Agreement.

  • General partnership means an organization formed under chapters 45-13 through 45-21.

  • Operating Partnership has the meaning set forth in the preamble.

  • Operating Companies shall have the meaning specified in the recitals to this Agreement.

  • General Partners means all such Persons.

  • Partnership Property means any property, real, personal or mixed, or any interest therein or appurtenant thereto which may be owned or acquired by the Partnership.

  • Operating Company means an “operating company” within the meaning of 29 C.F.R. §2510.3-101(c) of the Plan Asset Regulations.

  • GP means Gottbetter & Partners, LLP.

  • REIT means a real estate investment trust under Sections 856 through 860 of the Code.

  • Partnership has the meaning set forth in the preamble of this Agreement.

  • Partnership Subsidiary means Host LP and any partnership, limited liability company, or other entity treated as a partnership for federal income tax purposes or disregarded as a separate entity for federal income tax purposes in which either Host REIT or Host LP owns (or owned on or after January 1, 1999) an interest, either directly or through one or more other partnerships, limited liability companies or other entities treated as a partnership for federal income tax purposes or disregarded as a separate entity for federal income tax purposes (whether or not Host REIT or Host LP has a controlling interest in, or otherwise has the ability to control or direct the operation of, such entity). Notwithstanding the foregoing, the term “Partnership Subsidiary” shall not in any way be deemed to include the Non-Controlled Subsidiaries or subsidiaries thereof, the Taxable REIT Subsidiaries or subsidiaries thereof, or the Subsidiary REITs or subsidiaries thereof.

  • Operating Partnership Agreement means the Amended and Restated Agreement of Limited Partnership of the Operating Partnership, as it may be amended, supplemented or restated from time to time.

  • Surviving Partnership has the meaning set forth in Section 11.2.B(ii) hereof.

  • General Partner means the Company or its successors as general partner of the Partnership.

  • Business Partner means a legal entity that requires use of a Cloud Service in connection with Customer’s and its Affiliates’ internal business operations. These may include customers, distributors, service providers and/or suppliers of Customer.

  • Operating Entities means, from time to time, the Persons in which the Holding Entities, directly or indirectly, hold interests and that (i) directly hold real estate assets, or (ii) indirectly hold real estate assets but all of the interests of which are not held, directly or indirectly, by the Holding Entities, other than, in the case of each of (i) and (ii), any Person in which the Holding Entities, directly or indirectly, hold interests for investment purposes only of less than 5% of the outstanding equity securities of that Person;

  • Foreign limited partnership means a partnership formed under laws other than of this state and having as partners one or more general partners and one or more limited partners.

  • ETP means Energy Transfer Partners, L.P., a Delaware limited partnership.

  • General Partnership Interest means a Partnership Interest held by the General Partner that is a general partnership interest.

  • MLP has the meaning given such term in the introduction to this Agreement.

  • REIT Partner means (a) the General Partner or any Affiliate of the General Partner to the extent such person has in place an election to qualify as a REIT and, (b) any Disregarded Entity with respect to any such Person.

  • Partnership Group Member means any member of the Partnership Group.

  • Taxable REIT Subsidiary means any corporation (other than a REIT) in which General Partner directly or indirectly owns stock and General Partner and such corporation jointly elect that such corporation shall be treated as a taxable REIT subsidiary of General Partner under and pursuant to Section 856 of the Code.

  • Borrower Partnership Agreement means the Limited Partnership Agreement of the Borrower dated as of January 17, 2014 as such agreement may be amended, restated, modified or supplemented from time to time with the consent of the Administrative Agent or as permitted under Section 10.10.

  • Holding Entities means the subsidiaries of Brookfield Renewable Energy L.P., from time to time, through which it indirectly holds all of the Partnership’s interests in the Operating Entities.

  • Joint Ventures means the joint venture or partnership or other similar arrangements (other than between the Company and the Operating Partnership) in which the Company or the Operating Partnership or any of their subsidiaries is a co-venturer, limited liability company member, limited partner or general partner, which are established to acquire or hold Investments.