Cumulative Net Realized Tax Benefit definition

Cumulative Net Realized Tax Benefit for a Taxable Year means the cumulative amount of Realized Tax Benefits for all Taxable Years of the Corporate Taxpayer, up to and including such Taxable Year, net of the cumulative amount of Realized Tax Detriments for the same period. The Realized Tax Benefit and Realized Tax Detriment for each Taxable Year shall be determined based on the most recent Tax Benefit Schedule or Amended Schedule, if any, in existence at the time of such determination.
Cumulative Net Realized Tax Benefit is defined in Section 3.1(b)(iii) of this Agreement.
Cumulative Net Realized Tax Benefit is defined in Section 3.1(b)(iii).

Examples of Cumulative Net Realized Tax Benefit in a sentence

Notwithstanding the previous sentence, any resolution by the Corporation pursuant to this Section 6.08(a) shall reflect a reasonable interpretation of the provisions of this Agreement, consistent with the goal that the provisions of this Agreement result in the TRA Holders receiving eighty-five percent (85%) of the Cumulative Net Realized Tax Benefit and the Additional Amount thereon.


More Definitions of Cumulative Net Realized Tax Benefit

Cumulative Net Realized Tax Benefit for a taxable year means the cumulative amount of Realized Tax Benefits for all taxable years or portions thereof beginning after the date hereof of (i) Corporate Taxpayer and (ii) its wholly-owned Subsidiaries, up to and including such taxable year, net of the cumulative amount of Realized Tax Detriments for the same period. The Realized Tax Benefit and Realized Tax Detriment for each taxable year or portion thereof shall be determined based on the most recent Tax Benefit Schedule or Amended Schedule (and the most recent schedules or amended schedules described in the Other Tax Receivable Agreements), if any, in existence at the time of such determination. If a Cumulative Net Realized Tax Benefit is being calculated with respect to a portion of a taxable year (e.g., if a relevant taxable year does not close on the date hereof), then calculations of the Cumulative Net Realized Tax Benefit (including determinations relating to NOLs, Basis Adjustments and Imputed Interest to the extent applicable) shall be made as if there were an interim closing of the books of the relevant entity and its Subsidiaries and the taxable year had closed on the relevant date (e.g., the date hereof if a relevant taxable year does not close on the date hereof).
Cumulative Net Realized Tax Benefit in respect of an Exchanging Member for a Taxable Year means the cumulative amount of Realized Tax Benefits in respect of such Exchanging Member for all Taxable Years of the Corporation, up to and including such Taxable Year, net of the cumulative amount of Realized Tax Detriments in respect of such Exchanging Member for the same period. The Realized Tax Benefit and Realized Tax Detriment in respect of an Exchanging Member for each Taxable Year shall be determined based on the most recent Tax Benefit Schedule or Amended Schedule in respect of such Exchanging Member, if any, in existence at the time of such determination.
Cumulative Net Realized Tax Benefit as of the end of a Taxable Year means the cumulative amount of Realized Tax Benefits for all Taxable Years of the Corporation (excluding, for the avoidance of doubt, the Taxable Years of the Blockers ending on the Closing Date), up to and including such Taxable Year, net of the cumulative amount of Realized Tax Detriments of the Corporation for the same period. The Realized Tax Benefit and Realized Tax Detriment for each Taxable Year shall be based on the most recent Tax Benefit Schedules or Amended Schedules, if any, in existence at the time of such determination.
Cumulative Net Realized Tax Benefit means for a taxable year in respect of an LLC Unit Holder the cumulative amount of Realized Tax Benefits in respect of such LLC Unit Holder for all taxable years or portions thereof of (i) Corporate Taxpayer, (ii) its wholly-owned Subsidiaries, and (iii) without duplication, Habit LLC and its Subsidiaries, up to and including such taxable year, net of the cumulative amount of Realized Tax Detriments in respect of such LLC Unit Holder for the same period. The Realized Tax Benefit and Realized Tax Detriment in respect of such LLC Unit Holder for each taxable year or portion thereof shall be determined based on the most recent Tax Benefit Schedule or Amended Schedule, if any, in existence at the time of such determination. If a Cumulative Net Realized Tax Benefit in respect of such LLC Unit Holder is being calculated with respect to a portion of a taxable year, then calculations of the Cumulative Net Realized Tax Benefit in respect of such LLC Unit Holder (including determinations relating to Basis Adjustments and Imputed Interest to the extent applicable) shall be made as if there were an interim closing of the books of the relevant entity and its Subsidiaries and the taxable year had closed on the relevant date.
Cumulative Net Realized Tax Benefit is defined in Section 3.02(c).
Cumulative Net Realized Tax Benefit for a Taxable Year equals the positive excess, if any, of the cumulative amount of Overall Realized Tax Benefits Allocable to the Participant for all Taxable Years of the Corporation, up to and including such Taxable Year, over the cumulative amount of Overall Realized Tax Detriments Allocable to the Participant for the same period.
Cumulative Net Realized Tax Benefit for a Taxable Year means the cumulative amount of Realized Tax Benefits for all Taxable Years of the Corporate Taxpayer ending after December 31, 2025, up to and including such Taxable Year, net of the cumulative amount of Realized Tax Detriments for the same period; provided that, if the Corporate Taxpayer chooses to exercise its right of early termination under Section 4.1(a) or the Corporate Taxpayer’s obligations under this Agreement are accelerated under Section 4.1(b) or Section 4.1(c), such period used for purposes of determining the Early Termination Payment shall include any Taxable Year of the Corporate Taxpayer ending on or after the Early Termination Date without regard to whether such relevant Taxable Year ends on or before December 31, 2023. The Realized Tax Benefit and Realized Tax Detriment for each Taxable Year shall be determined based on the most recent Tax Benefit Schedules or Amended Schedules, if any, in existence at the time of such determination.