Disposition Gain means, for each Fiscal Year of the Trust, the Series’ aggregate recognized gain (including the portion thereof, if any, treated as ordinary income) resulting from each disposition of Series assets during such Fiscal Year with respect to which gain or loss is recognized for federal income tax purposes, including, without limitation, any gain or loss required to be recognized by the Series for federal income tax purposes pursuant to Section 988 or 1256 (or any successor provisions) of the Code.
Disposition Gain means, with respect to a Disposition of any Bond or portion thereof, the excess, if any, of the amount realized from such Disposition as determined under applicable Code provisions, over the Accreted Price of such Bond (including, if applicable, any Bond Redemption Premium) or portion of such Bond.
Disposition Gain means, for each Fiscal Year of the Trust, the Series' aggregate recognized gain (including the portion thereof, if any, treated as ordinary income) resulting from each disposition of Series assets during such Fiscal Year with respect to which gain or loss is recognized for federal income tax purposes, including, without limitation, any gain or loss required to be recognized by the Series for federal income tax purposes pursuant to Section 988 or 1256 (or any successor provisions) of the Code.
Examples of Disposition Gain in a sentence
Except as otherwise provided herein, such allocations of profit and loss shall be pro rata from Disposition Gain (or Disposition Loss) and Profits (or Losses).
After giving effect to the special allocations set forth in Sections 8.4 and 8.5 (but before making any special allocations of Disposition Gain or Disposition Loss under Section 8.3), Net Profit for each Fiscal Year shall be allocated to the Members in accordance with their respective Percentage Interests.
More Definitions of Disposition Gain
Disposition Gain means, with respect to each Fund, for each Fiscal Year, the Fund’s aggregate recognized gain (including the portion thereof, if any, treated as ordinary income) resulting from each disposition of Fund assets during such Fiscal Year with respect to which gain or loss is recognized for Federal income tax purposes, including, without limitation, any gain or loss required to be recognized by the Fund for Federal income tax purposes pursuant to Sections 988 or 1256 (or any successor provisions) of the Code.
Disposition Gain means, for each Contributed Asset, any income or gain that is recognized by a Property Owner or the Company for federal income tax purposes as a result of a Disposition of the Contributed Asset and is allocated to a Protected Party provided that the amount of such gain can never exceed the amount of the Section 704(c) Gain attributable to the Contributed Asset as of the date of contribution to the Company.
Disposition Gain means, in respect of each Fiscal Year of the Master Fund, the Master Fund’s aggregate recognized gain (including the portion thereof, if any, treated as ordinary income) resulting from each disposition of Master Fund assets during such Fiscal Year with respect to which gain or loss is recognized for U.S. federal income tax purposes, including, without limitation, any gain or loss required to be recognized by the Master Fund for U.S. federal income tax purposes pursuant to Section 988 or 1256 (or any successor provisions) of the Code.
Disposition Gain. ' means, with respect to a Disposition of any Asset or portion thereof, the excess, if any, of the amount realized from such Disposition as determined under applicable Code provisions, over the Accreted Price of such Asset (including, if applicable, any Bond Redemption Premium) or portion of such Asset.
Disposition Gain means, with respect to a Disposition of any Deposited Asset or portion thereof, the excess, if any, of the amount realized from such Disposition as determined under applicable Code provisions, over the Accreted Price of such Deposited Asset (including, if applicable, any Deposited Asset Redemption Premium) or portion of such Deposited Asset.
Disposition Gain means, with respect to a Disposition of any Asset or portion thereof, the excess, if any, of the amount realized from such Disposition as determined under applicable Code provisions, over the Accreted Price of such Asset (including, if applicable, any Redemption Premium) or portion of such Asset.
Disposition Gain means (i) with respect to the Disposition of a Portfolio Asset, the excess (if any) of the amount realized from such Disposition over the U.S. federal income tax basis of the Class B Arrangement in such Portfolio Asset, (ii) with respect to a partial payment of Portfolio Asset Principal, the product of (A) the amount of such Portfolio Asset Principal payment and (B) the difference between 100% less the U.S. federal income tax basis of the Class B Arrangement in the portion of Portfolio Asset partially paid, expressed as a percentage, provided, if (B) is a negative number, the Disposition Gain shall be zero, (iii) with respect to a Mandatory Tender, the portion of the Purchase Price paid in connection with such Mandatory Tender pursuant to Section 4.03(c)(iii), or (iv) with respect to a payment of Portfolio Asset Premium, the amount of Portfolio Asset Premium received by the Trustee in respect of such Portfolio Asset. 0000-0000-0000.8