Attributable. A Net Tax Benefit is “Attributable” to a TRA Holder to the extent that it is derived from any Basis Adjustment, Imputed Interest or Actual Interest Amount that is attributable to an Exchange undertaken by or with respect to such TRA Holder .
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Samples: Business Combination Agreement (Trebia Acquisition Corp.), Tax Receivable Agreement (System1, Inc.)
Attributable. A Net Tax Benefit is “Attributable” to a TRA Holder Party to the extent that it is derived from any Basis Adjustment, Adjustment or Imputed Interest or Actual Interest Amount that is attributable to an Exchange a Basis Transaction undertaken by or with respect to such TRA Holder Party.
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Samples: Limited Liability Company Agreement (ARYA Sciences Acquisition Corp IV), Limited Liability Company Agreement (Amicus Therapeutics, Inc.)
Attributable. A Net Tax Benefit is “Attributable” to a TRA Holder Party to the extent that it is derived from any Basis Adjustment, Adjustment or Imputed Interest or Actual Interest Amount that is attributable to arising as a result of an Exchange undertaken by or with respect to such TRA Holder Party.
Appears in 2 contracts
Samples: Tax Receivable Agreement (Solo Brands, Inc.), Tax Receivable Agreement (Solo Brands, Inc.)
Attributable. A Net Tax Benefit is “Attributable” to a an TRA Holder to the extent that it is derived from any Basis Adjustment, Adjustment or Imputed Interest or Actual Interest Amount that is attributable to an Exchange undertaken by or with respect to such TRA Holder (whether through an Exchange), determined without regard to any dilutive or antidilutive effect of any contribution to or distribution from the Company after an applicable Exchange.
Appears in 2 contracts
Samples: Operating Agreement (EG Acquisition Corp.), Tax Receivable Agreement (Flyexclusive Inc.)
Attributable. A Net Tax Benefit is “Attributable” to a an TRA Holder to the extent that it is derived from any Common Basis, Basis Adjustment, or Imputed Interest or Actual Interest Amount Interest, that is attributable to such TRA Holder (whether through an Exchange undertaken by or with respect Exchange, which in the case of Common Basis shall be based on the Common Basis attributable to such TRA Holder Holder’s LLC Units subject to a given Exchange for U.S. federal income tax purposes as of immediately prior to the applicable Exchange(s)), determined without regard to any dilutive or antidilutive effect of any contribution to or distribution from the LLC after an applicable Exchange.
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