Change in U.S. Tax Treaty definition

Change in U.S. Tax Treaty means the enactment, promulgation, execution or ratification of, or any amendment to, any tax treaty to which the United States is a party, which, in each case, (a) occurs on or after the later of (i) January 29, 2009 or (ii) with respect to any assignment or granting of participating interests, the date of the applicable assignment or grant, and (b) has not been initially publicly announced or otherwise publicly indicated by a Governmental Authority to be negotiated or intended to be negotiated, and distributed or publicized on or through media generally or readily available to lenders, financial institutions, investment funds or their advisers, including by subscription or other charge, prior to the later of (i) January 29, 2009 or (ii) with respect to any assignment or granting of participating interests, the date of the applicable assignment or grant. “Change in U.S. Tax Treaty Prepayment” has the meaning set forth in clause (g) of Section 13.1.
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Examples of Change in U.S. Tax Treaty in a sentence

  • Each prepayment of the Loan shall be in a minimum amount of $250,000 or a higher integral multiple of $50,000, except as necessary to apply fully the required amount of any Net Proceeds Prepayment, Change of Control Prepayment or Change in U.S. Tax Treaty Prepayment.

Related to Change in U.S. Tax Treaty

  • Change in Tax Law means the enactment, promulgation, execution or ratification of, or any change in or amendment to, any law (or in the application or official interpretation of any law) that occurs on or after the date on which the relevant Transaction is entered into.

  • tax treaty means an agreement for the avoidance of double taxation entered into between South Africa and another country;

  • Intended Tax Treatment has the meaning set forth in the Recitals.

  • Tax Treatment [One or more elections will be made to treat the assets of the Trust Fund as a REMIC.] [The Trust Fund will be treated as a "grantor trust" for federal income tax purposes.]

  • Tax Law Change means a change in or proposed change in, or amendment or proposed amendment to, the laws or regulations of the United Kingdom or any political subdivision or any authority thereof or therein having the power to tax, including any treaty to which the United Kingdom is a party, or any change in the application of official or generally published interpretation of such laws or regulations, including a decision of any court or tribunal, or any interpretation or pronouncement by any relevant tax authority that provides for a position with respect to such laws or regulations or interpretation thereof that differs from the previously generally accepted position in relation to similar transactions, which change or amendment becomes, or would become, effective on or after the Issue Date;

  • Transaction Tax Deductions means any Tax deductions relating to (i) any pay down or satisfaction of Company Indebtedness or other Indebtedness, (ii) the payment or incurrence of any Transaction Expenses or Transaction Bonus Payments and (iii) any other deductible payments attributable to the Contemplated Transactions economically borne by the Seller. For this purpose, any success-based fees shall be treated as deductible in accordance with Rev. Proc. 2011-29.

  • U.S. Tax Code means the United States Internal Revenue Code of 1986, as amended; and

  • FATCA Withholding Tax means any withholding or deduction required pursuant to FATCA.

  • Change in Use means altering the purpose of an existing room, within the facility, that requires structural changes.

  • Section 409A Change in Control means a change in the ownership or effective control of the Company, or in the ownership of a substantial portion of the Company’s assets, as provided in Section 409A(a)(2)(A)(v) of the Code and Treasury Regulations Section 1.409A-3(i)(5) (without regard to any alternative definition thereunder).

  • Change in 1940 Act Law shall have the meaning set forth in the definition of "Investment Company Event."

  • Swiss Withholding Tax Act means the Swiss Federal Act on Withholding Tax of 13 October 1965 (Bundesgesetz über die Verrechnungssteuer), together with the related ordinances, regulations and guidelines, all as amended and applicable from time to time.

  • UK Tax Deduction means a deduction or withholding for, or on account of, Tax imposed by the United Kingdom from a payment under a Loan Document.

  • council tax benefit means council tax benefit under Part 7 of the SSCBA; “couple” has the meaning given by paragraph 4;

  • Presumed Tax Rate means the highest effective marginal statutory combined U.S. federal, state and local income tax rate prescribed for an individual residing in New York City (taking into account (i) the deductibility of state and local income taxes for U.S. federal income tax purposes, assuming the limitation of Section 68(a)(2) of the Code applies and taking into account any impact of Section 68(f) of the Code, and (ii) the character (long-term or short-term capital gain, dividend income or other ordinary income) of the applicable income).

  • Change in Control Transaction means the occurrence of any of the following events:

  • Change in Control Event means any of the following:

  • FATCA Withholding means any withholding or deduction required pursuant to an agreement described in section 1471(b) of the Code, or otherwise imposed pursuant to sections 1471 through 1474 of the Code, any regulations or agreements thereunder, any official interpretations thereof, or any law implementing an intergovernmental approach thereto.

  • Tax Law means the law of any governmental entity or political subdivision thereof relating to any Tax.

  • Treaty means the Treaty establishing the European Community, as amended.

  • Tax Detriment means an increase in the Tax liability (or reduction in refund or credit or any item of deduction or expense) of a Taxpayer for any taxable period. Except as otherwise provided in this Agreement, a Tax Detriment shall be deemed to have been realized or incurred from a Tax Item in a taxable period only if and to the extent that the Tax liability of the Taxpayer for such period, after taking into account the effect of the Tax Item on the Tax liability of such Taxpayer in the current period and all prior periods, is more than it would have been had such Tax liability been determined without regard to such Tax Item.

  • Actual Tax Liability means, with respect to any Taxable Year, the liability for Covered Taxes of the Corporation (a) appearing on Tax Returns of the Corporation for such Taxable Year and (b) if applicable, determined in accordance with a Determination (including interest imposed in respect thereof under applicable law).

  • Income Tax Act means the Income Tax Act, 1962 (Act No. 58 of 1962);

  • Swiss Withholding Tax means any withholding tax in accordance with the Swiss Federal Statute on Anticipatory Tax of 13 October 1965 (Bundesgesetz uber die Verrechnungssteuer) and any successor provision, as appropriate.

  • Tax Ruling as used in this Agreement, shall mean a written ruling of a taxing authority relating to Taxes. "Closing Agreement", as used in this Agreement, shall mean a written and legally binding agreement with a taxing authority relating to Taxes.