Tax Aspects. Exhibit B hereto contains a brief summary of certain federal tax aspects that may be relevant to holders of Management Units and includes a Section 83(b) election form. By signing this Agreement, the Participant represents that the Participant has reviewed with his/her own tax advisor the United States federal, state, local and non-United States tax consequences of the transactions contemplated by this Agreement (including whether or not to make a Section 83(b) election in connection with the receipt of capital interests) and that the Participant is relying solely on such advisor and not any statements or representations of Management LLC, Tower USA or any of their Affiliates or agents (including, without limitation, any statements in this Agreement or Exhibit B). The Participant acknowledges that it is the Participant’s sole responsibility and not that of Management LLC or Tower USA, or any of their Affiliates, to file timely the election under Section 83(b) of the Internal Revenue Code of 1986, as amended, even if the Participant requests Management LLC, Tower USA or any of their respective representatives to make this filing on the Participant’s behalf. [The remainder of this page is left intentionally blank.]
Tax Aspects. For so long as the Company has only one Member, for tax purposes it is intended that the Company be disregarded as an entity separate from its sole Member, in accordance with Treas. Reg. § 301.7701-3(b)(1)(ii).
Tax Aspects. The Parties shall agree in a separate schedule, if appropriate, on provisions relating to the tax aspects of Transactions.
Tax Aspects. 41 ADDITIONAL ASPECTS OF LLC AGREEMENT...................................................................................73 LIABILITY.............................................................................................................78
Tax Aspects. (a) The VRV Group has always acted in full compliance with all tax, currency and social security Laws applicable to the same, duly and timely fulfilling all obligations and provisions originating from time to time from said Laws.
Tax Aspects equity component of the portfolio would be subjected to short term/long term capital gains tax depending on the holding period of the security. If the holding period is less than one year, a 15% short term capital gains tax would be applicable. If the holdings period is more than one year, a 10% long term capital gains tax would be applicable on portfolio gains. These rates can be revised on a time to time basis by the government of India. Tax liability on the ETF component of the portfolio, if any, would depend on the underlying asset class of the ETF. When in doubt, client shall reach out to the Investment Advisor on the mentioned email id for a detailed evaluation based on the trades placed by the client.
Tax Aspects. All tax returns of the Company have been timely and duly filed with the competent Governmental Authorities in all jurisdictions in which such filings are required to be filed and such tax returns are true, complete and correct. All Taxes due by the Company have been duly paid (and until the Closing Date shall, within the time prescribed by Law, be paid) on their due dates, or, where payment is not yet due, the Company has made adequate provision for all Taxes in the Financial Statements in accordance with IFRS. The Company is not currently subject to any audit or inspection by any Governmental Authority in respect of Tax matters and no such audit or inspection is threatened. With exception of the fiscal programs indicated in Schedule 5.2.9, the Company has not (i) entered into any agreements with Tax Governmental Authorities for the payment of late Taxes; (ii) received any notice or been a party to any judicial or administrative proceeding for the collection of Taxes; or (iii) benefitted from any Tax amnesty in the last 5 (five) years. There is no outstanding assessment, dispute, proceeding, investigation or claim concerning any Tax liability of the Company claimed, pending or raised by a Tax Governmental Authority in writing, and no such assessment, dispute, proceeding, investigation or claim has been threatened. There are no Encumbrances for Taxes upon any property or assets of the Company. There are no outstanding agreements, waivers or written arrangements extending the statutory period of limitations applicable to any claim for, or the period for the collection or assessment of, Taxes due from or with respect to the Company. All Taxes required to be withheld, accrued, collected or deposited by or with respect to the Company have been timely and accurately withheld, accrued, collected or deposited and, to the extent required, have been paid to the relevant Tax Governmental Authority. The Company and is not subject to taxation in any jurisdiction other than Brazil. The Company does not have any Liability for the Taxes of any other Person under applicable Tax laws, as a transferee or successor, by contract, or otherwise. The Company is not a party to, nor is bound by, or has any obligation under, any tax allocation or sharing agreement or similar contract or arrangement or any agreement that obligates it to make any payment computed by reference to the Taxes, taxable income or taxable losses of any other Person. 5.2.9
Tax Aspects. I have considered to the extent I or my own advisors believe appropriate regarding all state and federal income tax aspects relating to the Company.
Tax Aspects. (i) The relevant income tax due for the activity performed by the Influencer shall be determined using the gross up method, by taking in consideration the provisions of the Law 227/2015 regarding the Fiscal code, as subsequently amended and supplemented (including, but not limited to, the flat-rate quota to be considered as deduction), applicable at the date when the tax is computed. The income tax determined as such, shall be declared to the tax authorities and paid to the state budget by the Provider, in accordance with the provisions of the Law 227/2015 regarding the Fiscal code, as subsequently amended and supplemented.
Tax Aspects. The conversion of the foreign currency for determining the taxable base of the tax obligations derived from customs transactions will be made at the exchange rate for purchase of the foreign currency of the transaction involved; in the case of foreign currency owned by the importer, the applicable rate will be the weighted average exchange rate of cross exchange transactions and exchange transactions with securities in foreign currency to which article 24 of EA33 refers, published by the VCB on the date of payment of the tax obligation. The tax obligations established in special laws, as well as the rates, commissions, surcharges, and public prices fixed in foreign currency, may be paid alternatively in foreign currency or in bolivars, at the weighted average exchange rate of cross exchange transactions and exchange transactions with securities in foreign currency to which article 24 of EA33 refers, published by the VCB on the date of the relevant payment.
