Common use of Attributable Clause in Contracts

Attributable. A Net Tax Benefit is “Attributable” to a Member to the extent that it is derived from any Basis Adjustment or Imputed Interest that is attributable to an Exchange undertaken by or with respect to such Member.

Attributable. A Net Tax Benefit is “Attributable” to a Member to the extent that it is derived from any Basis Adjustment Adjustment, Imputed Interest, or Imputed Actual Interest Amount that is attributable to an Exchange undertaken by or with respect to such Member.

Attributable. A Net Tax Benefit is “Attributable” to a Member to the extent that it is derived from any Basis Adjustment or Imputed Interest that is attributable to arising as a result of an Exchange undertaken by or with respect to such Member.

Attributable. A Net Tax Benefit is “Attributable” to a Member TRA Payment Recipient to the extent that it is derived from any Basis Adjustment or Imputed Interest that is attributable to an Exchange undertaken by or with respect to such MemberTRA Payment Recipient.

Attributable. A Net Tax Benefit that is “Attributable” to a Member with respect to any Exchange Covered Tax Assets shall be determined separately with respect to each Member and each Exchange undertaken by or with respect such Member in an amount equal to the extent that it is derived from any Basis Adjustment or Imputed Interest that is attributable total Exchange Covered Tax Assets relating to an Exchange undertaken the Units Exchanged by or with respect to such Member.

Attributable. A Net Tax Benefit is “Attributable” to a Member to the extent that it is derived from (A) any Basis Adjustment or Imputed Interest that is attributable to an Exchange a Basis Transaction undertaken by or with respect to such Member, (B) any Section 704(c) Benefit to the Corporation to the extent such Section 704(c) Benefit increased the taxable income (or decreased the taxable loss or tax deductions) allocated to such Member, or (C) Section 707(c) Deductions resulting from payments made to such Member.

Attributable. A Net Tax Benefit is “Attributable” to a Member to the extent that it is derived from any Basis Adjustment Adjustment, Imputed Interest, or Imputed Actual Interest Amount that is attributable to an Exchange undertaken by or with respect to such MemberMember or is attributable to a Reverse Section 704(c) Allocation that otherwise would have been allocated to such Member if Xxxx Holdings was not required to make such Reverse Section 704(c) Allocation.

Attributable. A Net Tax Benefit is “Attributable” to a Member to the extent that it is derived from any Basis Adjustment Adjustment, Imputed Interest, or Imputed Actual Interest Amount that is attributable to an Exchange undertaken by or with respect to such Member or a Specified Section 734(b) Basis Adjustment Transaction with respect to such Member.

Attributable. A Net Tax Benefit is “Attributable” to a Member an Exchange TRA Holder to the extent that it is derived from any Basis Adjustment or Imputed Interest Interest, that is attributable to such Exchange TRA Holder (whether through an Exchange undertaken by or with respect to such Memberotherwise).

Attributable. A Net Tax Benefit is “Attributable” to a Member to the extent that it is derived from any Basis Adjustment Adjustment, Imputed Interest, Actual Interest Amount or Imputed Default Rate Interest that is attributable to arising as a result of an Exchange undertaken by or with respect to such Member.

Attributable. A Net Tax Benefit is “Attributable” to a Member Beneficiary to the extent that it is derived from any Basis Adjustment or Imputed Interest that is attributable to an Exchange undertaken by or with respect to such MemberBeneficiary or from any Pre-IPO NOL that is deemed attributable to such Beneficiary; provided, that, in the case of any Net Tax Benefit Attributable to the Merger, such Net Tax Benefit shall be Attributable to each former shareholder of AOTG on a pro rata basis in accordance with their ownership interests, as provided on Exhibit A hereto.