Realized Tax Detriment. The “Realized Tax Detriment” for a Taxable Year equals the excess, if any, of the Actual Tax Liability over the Hypothetical Tax Liability for such Taxable Year. If all or a portion of the Actual Tax Liability for such Taxable Year arises as a result of an audit or similar proceeding by a Taxing Authority of any Taxable Year, such liability shall not be included in determining the Realized Tax Detriment unless and until there has been a Determination.
Appears in 42 contracts
Samples: Tax Receivable Agreement (Switch, Inc.), Tax Receivable Agreement (Bridge Investment Group Holdings Inc.), Tax Receivable Agreement (MedMen Enterprises, Inc.)
Realized Tax Detriment. The “Realized Tax Detriment” for a Taxable Year equals the excess, if any, of the Actual Tax Liability over the Hypothetical Tax Liability for such Taxable Year. If all or a portion of the Actual Tax Liability for such Taxable Year arises as a result of an audit or similar proceeding by a Taxing Authority of any Taxable Year, such liability and the corresponding Hypothetical Tax Liability shall not be included in determining the Realized Tax Detriment unless and until there has been a Determination.
Appears in 8 contracts
Samples: Tax Receivable Agreement (Brilliant Earth Group, Inc.), Tax Receivable Agreement (Brilliant Earth Group, Inc.), Joinder Agreement (Ascendant Digital Acquisition Corp.)
Realized Tax Detriment. The “Realized Tax Detriment” for a Taxable Year equals the excess, if any, of the Actual Tax Liability actual liability of the Corporation for Covered Taxes over the Hypothetical Tax Liability for such Taxable Year. If all or a portion of the Actual Tax Liability actual liability for such Covered Taxes for the Taxable Year arises as a result of an audit or similar proceeding by a Taxing Authority of any Taxable Year, such liability shall not be included in determining the Realized Tax Detriment unless and until there has been a Determination.
Appears in 5 contracts
Samples: Tax Receivable Agreement (Neff Corp), Tax Receivable Agreement (Bioventus Inc.), Tax Receivable Agreement (Neff Corp)
Realized Tax Detriment. The “Realized Tax Detriment” for a Taxable Year equals the excess, if any, of (a) the Actual Tax Liability over (b) the Hypothetical Tax Liability for such Taxable Year. If all or a portion of the Actual Tax Liability for such the Taxable Year arises as a result of an audit or similar proceeding by a Taxing Authority of any Taxable Year, such liability shall not be included in determining the Realized Tax Detriment unless and until there has been a Determination.
Appears in 5 contracts
Samples: Tax Receivable Agreement (Bitcoin Depot Inc.), Limited Liability Company Agreement (Horizon Acquisition Corp), Tax Receivable Agreement (GSR II Meteora Acquisition Corp.)
Realized Tax Detriment. The “Realized Tax Detriment” for a Taxable Year equals the excess, if any, of the Actual Tax Liability actual liability of Holdings for Covered Taxes over the Hypothetical Tax Liability for such Taxable Year. If all or a portion of the Actual Tax Liability actual liability for such Covered Taxes for the Taxable Year arises as a result of an audit or similar proceeding by a Taxing Authority of any Taxable Year, such liability shall not be included in determining the Realized Tax Detriment unless and until there has been a Determination.
Appears in 4 contracts
Samples: Tax Receivable Agreement (RE/MAX Holdings, Inc.), Tax Receivable Agreement (RE/MAX Holdings, Inc.), Tax Receivable Agreement (RE/MAX Holdings, Inc.)
Realized Tax Detriment. The “Realized Tax Detriment” for a Taxable Year equals the excess, if any, of the Actual Tax Liability over the Hypothetical Tax Liability for such Taxable Year. If all or a portion of the Actual Tax Liability for such Taxable Year arises as a result of an audit or similar proceeding by a Taxing Authority of any Taxable Year, such liability and the corresponding impact on the Hypothetical Tax Liability as a result of such audit or similar proceeding, if applicable, shall not be included in determining the Realized Tax Detriment unless and until there has been a Determination.
Appears in 2 contracts
Samples: Registration Rights Agreement (Inflection Point Acquisition Corp.), Tax Receivable Agreement (Intuitive Machines, Inc.)
Realized Tax Detriment. The “Realized Tax Detriment” for a Taxable Year equals the excess, if any, of the Actual Tax Liability over the Hypothetical Tax Liability for such Taxable Year. If all or a portion of the Actual Tax Liability for such Taxable Year arises as a result of an audit or similar proceeding by a Taxing Authority of any Taxable Year, such liability (and any corresponding adjustments to the Hypothetical Tax Liability) shall not be included in determining the Realized Tax Detriment unless and until there has been a Determination.
Appears in 2 contracts
Samples: Tax Receivable Agreement (Definitive Healthcare Corp.), Tax Receivable Agreement (Definitive Healthcare Corp.)
Realized Tax Detriment. The “Realized Tax Detriment” for a Taxable Year equals the excess, if any, of the Actual Tax Liability of the Corporation for Covered Taxes over the Hypothetical Tax Liability for such Taxable Year. If all or a portion of the Actual Tax Liability for such Covered Taxes for the Taxable Year arises as a result of an audit or similar proceeding by a Taxing Authority of any Taxable Year, such liability shall not be included in determining the Realized Tax Detriment unless and until there has been a Determination.
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