Special Tax Treatment Sample Clauses

Special Tax Treatment. Capital gains treatment and 10-year forward income averaging authorized by IRC Sec. 402 do not apply to IRA distributions.
Sample 1Sample 2Sample 3See All (143)
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Special Tax Treatment. Capital gains treatment and 10-year income averaging authorized by IRC Sec. 402 do not apply to Xxxx XXX distributions.
Sample 1Sample 2Sample 3See All (114)
Special Tax Treatment. Capital gains treatment and 10-year forward income averaging authorized by Code Section 402 do not apply to XXX distributions.
Sample 1Sample 2See All (7)
Special Tax Treatment. Capital gains treatment and the favorable five or ten-year forward averaging tax under Code Section 402 do not apply to HSA distributions.
Sample 1Sample 2Sample 3See All (5)
Special Tax Treatment. Upon the contribution of all of the Contributed Interests to the Partnership as described in the Recitals to this Agreement, Eclipse I will be treated for federal income tax purposes (and state and local income tax purposes, as applicable) as merging with and into the Partnership in an assets-over form (as that term is defined in Treasury Regulation Section 1.708-1(c)(3)). In accordance with the provisions of Treasury Regulation Section 1.708-1(c)(1), the Partnership will be treated as a continuation of Eclipse I for federal income tax purposes (and state and local income tax purposes, as applicable) (including retaining the employer identification number of Eclipse I). The tax year of the Partnership, as the continuation of Eclipse I, shall not terminate as a result of such transactions.
Sample 1Sample 2
Special Tax Treatment. Capital gains treatment and 10-year forward income averaging authorized by Code section 402 do not apply to SIMPLE IRA distributions.
Sample 1Sample 2
Special Tax Treatment. If your eligible rollover distribution is not rolled over, it will be taxed in the year you receive it. However, if it qualifies as a "lump sum distribution," it may be eligible for special tax treatment. A lump sum distribution is a payment, within one year, of your entire balance under the Plan (and certain other similar plans of the employer) that is payable to you because you have reached age 59-1/2 or have separated from service with your employer (or, in the case of a self-employed individual, because you have reached age 59-1/2 or have become disabled). For a payment to qualify as a lump sum distribution, you must have been a participant in the Plan for at least 5 years. The special tax treatment for lump sum distributions is described below.
Sample 1
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Special Tax Treatment. Capital gains treatment and the favorable five or ten year forward averaging tax authorized by IRC Section 402 do not apply to XXX distributions.
Sample 1

Related to Special Tax Treatment

  • Intended Tax Treatment Notwithstanding anything to the contrary herein or in any other Transaction Document, all parties to this Agreement covenant and agree to treat each Loan under this Agreement as debt (and all Interest as interest) for all federal, state, local and franchise tax purposes and agree not to take any position on any tax return inconsistent with the foregoing.

  • Tax Treatment If any interest in any Loan Document is transferred to any Transferee which is organized under the laws of any jurisdiction other than the United States or any State thereof, the transferor Lender shall cause such Transferee, concurrently with the effectiveness of such transfer, to comply with the provisions of Section 3.5(iv).

  • Tax Treatment of Payments Except to the extent otherwise required pursuant to a “determination” (within the meaning of Section 1313(a) of the Code or any similar provision of state, local or foreign Law), Seller, Purchaser, the Company and their respective Affiliates shall treat any and all payments under this Article ‎VII, Section ‎‎2.7 and ‎Article ‎X as an adjustment to the Purchase Price for Tax purposes.

  • Federal Income Tax Treatment of the Trust (a) For so long as the Trust has a single owner for federal income tax purposes, it will, pursuant to Treasury Regulations promulgated under section 7701 of the Code, be disregarded as an entity distinct from the Certificateholder for all federal income tax purposes. Accordingly, for federal income tax purposes, the Certificateholder will be treated as (i) owning all assets owned by the Trust and (ii) having incurred all liabilities incurred by the Trust, and all transactions between the Trust and the Certificateholder will be disregarded.

  • Income Tax Characterization For purposes of federal income, state and local income and franchise and any other income taxes, the Issuer will, and each Noteholder by such Noteholder’s acceptance of any such Notes (and each Person who acquires an interest in any Notes through such Noteholder, by the acceptance by such Person of an interest in the applicable Notes) agrees to, treat the Notes that are characterized as indebtedness at the time of their issuance, and hereby instructs the Issuer to treat such Notes, as indebtedness for federal, state and other tax reporting purposes. Each Noteholder agrees that it will cause any Person acquiring an interest in a Note through it to comply with this Indenture as to treatment as indebtedness under applicable tax law, as described in this Section 3.21. The Notes will be issued with the intention that, for federal, state and local income and franchise tax purposes the Trust shall not be treated as an association or publicly traded partnership taxable as a corporation. The parties hereto agree that they shall not cause or permit the making, as applicable, of any election under Treasury Regulation Section 301.7701-3 (or any successor provision) whereby the Trust or any portion thereof would be treated as a corporation for federal income tax purposes. The provisions of this Indenture shall be construed in furtherance of the foregoing intended tax treatment.

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