Built-In Loss definition
Built-In Loss means with respect to any Property (a) the excess of the adjusted basis for U.S. federal income tax purposes of any Contributed Property over its Agreed Value as of the time of contribution and (b) in the case of any adjustment to the Gross Asset Value of any Property pursuant to the definition of Gross Asset Value, the Unrealized Loss with respect to that Property.
Built-In Loss with respect to any Partnership property means (i) the excess of its adjusted basis for federal income tax purposes of any Contributed Property over its Agreed Value as of the time of contribution and (ii) in the case of any adjustment to the Carrying Value of any Partnership property subject to depreciation, cost recovery or amortization pursuant to Section 8.4 as a result of a contribution of cash for a Partnership Interest, the Unrealized Loss with respect to such property.
Built-In Loss attributable to any Contributed Property means, as of the date of contribution, the excess of the adjusted federal income tax basis of such property over its fair market value.
Examples of Built-In Loss in a sentence
As of the Closing Date, none of the Backlog Contracts has, to Seller’s knowledge, a Built-In Loss.
The Company, for federal and other income tax purposes, shall, in the case of Contributed Properties, allocate items of income, gain, loss, depreciation and cost recovery deductions attributable to those properties with a Built-In Gain or Built-In Loss pursuant to section 704(c) of the Code under a method described in Treas.
The Company, GVN and GVS did not have a Net Unrealized Built-In Loss as defined in Internal Revenue Code Section 382(h) at the time of the March 3, 2003 ownership change.
More Definitions of Built-In Loss
Built-In Loss shall have the meaning set forth in Section 2.24.
Built-In Loss with respect to any Partnership property means (1) as of the time of contribution, the excess of the adjusted basis for federal income tax purposes of any Contributed Property over its Gross Asset Value, and (2) in the case of any adjustment to the Carrying Value of any Partnership property pursuant to this Agreement, the Unrealized Loss.
Built-In Loss means that the total amount of revenue attributed to a particular Backlog Contract is less than the total amount of costs incurred and estimated to be incurred, inclusive of all direct and indirect overhead cost, under such Backlog Contract. Except for the Backlog Contracts and the associated customer orders identified with an asterisk on Schedule 2.24(a) (the "Non-Standard Backlog Contracts”), all of the Backlog Contracts have the terms and conditions set forth in Schedule 2.24(b). Seller will deliver Schedules 2.24(a) and 2.24(b) at the Closing, but, if necessary, may update Schedule 2.24(a) within five (5) days after the Closing to reflect a final listing as of the Effective Time. The parties will get together within thirty (30) days following the Closing Date to determine what level of information that Buyer will have access to for purposes of carrying out its responsibilities with respect to the Backlog Contracts.
Built-In Loss means the difference between the Carrying Value of each item of Partnership property, as adjusted from time to time, and the adjusted basis thereof for federal income tax purposes.
Built-In Loss means (i) any operating loss attributable to the period prior to the Determination Date and (ii) cumulative differences attributable to book and tax balance sheet carrying amounts at the Determination Date including, without limitation, the difference between the adjusted tax basis and fair market value of the Company’s assets on the Determination Date (including for this purpose assets held by the Company’s subsidiaries).
Built-In Loss means the excess of the adjusted
Built-In Loss shall have the meaning set forth in Section 382(h) of the Code.