Electronics Business Tax Attribute definition

Electronics Business Tax Attribute means any Tax Attribute of any Electronics Entity attributable to the Electronics Business, as determined by Xxxxxxx Controls in good faith.
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Electronics Business Tax Attribute means any Tax Attribute of any Electronics Entity attributable to the Electronics Business, as determined by Xxxxxxx Controls in good faith. “Electronics Entity” means each of Xxxxxxx Controls Automotive Electronics do Brasil Ltda. (formerly SAGEM Do Brasil), JC International ZAO, and any of their respective successors. “Employee Matters Agreement” means the Employee Matters Agreement, dated as of September 8, 2016, by and between Xxxxxxx Controls and Adient. “Federal Income Tax” means any Tax imposed by Subtitle A of the Code. “Federal Other Tax” means any Tax imposed by the federal government of the United States of America other than any Federal Income Taxes. “Fifty-Percent or Greater Interest” has the meaning ascribed to such term for pur- poses of Sections 355(d) and (e) of the Code and the Treasury Regulations Thereunder. “Filing Date” has the meaning set forth in Section 6.04(d). “Final Determination” means the final resolution of liability for any Tax, which resolution may be for a specific issue or adjustment or for a Tax Period, (a) by IRS Form 870 or 870-AD (or any successor forms thereto), on the date of acceptance by or on behalf of the tax- payer, or by a comparable form under the Laws of a State, local or foreign taxing jurisdiction, except that a Form 870 or 870-AD or comparable form shall not constitute a Final Determination to the extent that it reserves (whether by its terms or by operation of Law) the right of the tax- payer to file a claim for Refund or the right of the Tax Authority to assert a further deficiency in respect of such issue or adjustment or for such Tax Period (as the case may be); (b) by a deci- sion, judgment, decree or other order by a court of competent jurisdiction, which has become fi- nal and unappealable; (c) by a closing agreement or accepted offer in compromise under Section 7121 or 7122 of the Code, or a comparable agreement under the Laws of a State, local or foreign taxing jurisdiction; (d) by any allowance of a Refund in respect of an overpayment of Tax, but
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Electronics Business Tax Attribute means any Tax Attribute of any Electronics Entity attributable to the Electronics Business, as determined by Johnson Controls in good faith.
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Related to Electronics Business Tax Attribute

  • Tax Attribute means a net operating loss, net capital loss, unused investment credit, unused foreign tax credit, excess charitable contribution, general business credit or any other Tax Item that could reduce a Tax.

  • Tax Attributes means net operating losses, capital losses, tax credit carryovers, earnings and profits, foreign tax credit carryovers, overall foreign losses, previously taxed income, tax bases, separate limitation losses and any other losses, deductions, credits or other comparable items that could affect a Tax liability for a past or future taxable period.

  • SpinCo Business has the meaning set forth in the Separation and Distribution Agreement.

  • Intra-Group Liabilities means the Liabilities owed by any member of the Group to any of the Intra-Group Lenders.

  • Certified Minority Business Enterprise means a business which has been certified by the certifying organization or jurisdiction in accordance with s. 287.0943(1) and (2).

  • Tax Period means, with respect to any Tax, the period for which the Tax is reported as provided under the Code or other applicable Tax Law.

  • SpinCo Group means (a) prior to the Effective Time, SpinCo and each Person that will be a Subsidiary of SpinCo as of immediately after the Effective Time, including the Transferred Entities, even if, prior to the Effective Time, such Person is not a Subsidiary of SpinCo; and (b) on and after the Effective Time, SpinCo and each Person that is a Subsidiary of SpinCo.

  • Unitary business means one or more related business organizations engaged in business activity both within and outside the State among which there exists a unity of ownership, operation, and use; or an interdependence in their functions.

  • Retained Business means any business now, previously or hereafter conducted by Seller or any of its Subsidiaries or Affiliates other than the Business.

  • Remainco Group means RemainCo and its Subsidiaries, other than the SpinCo Group.

  • Transferred Business has the meaning ascribed to such term in the Separation Agreement.

  • Separate Business means each of the activities of the Licensee connected

  • Production Tax Credit or “PTC” means the tax credit for electricity produced from certain renewable generation resources described in Section 45 of the Internal Revenue Code of 1986, as it may be amended or supplemented from time to time.

  • Deconsolidation shall have the meaning provided in the Recitals.

  • SpinCo Entities means the entities, the equity, partnership, membership, limited liability, joint venture or similar interests of which are set forth on Schedule IV under the caption “Joint Ventures and Minority Investments.”

  • Disadvantaged Business Enterprise (DBE) means a firm certified as such by the Department in accordance with 49 CFR Part 26.

  • SpinCo Liabilities shall have the meaning set forth in Section 2.3(a).

  • Retained Businesses means all businesses now, previously or hereafter conducted by Parent, the Sellers or any of their Subsidiaries or Affiliates, other than the Business.

  • Tax Items shall have the meaning set forth in Section 6.4.A.

  • MINORITY BUSINESS ENTERPRISE (MBE means an individual, partnership, corporation or joint venture of any kind that is owned and controlled by U. S. Citizens and residents of Ohio, who are and have held themselves out as members of the following socially and economically disadvantaged groups: Blacks, American Indians, Hispanics and Asians. Only businesses certified by the State of Ohio Equal Opportunity Division in accordance with Section 123.151 of the Ohio Revised Code shall be recognized as being MBE certified within the purpose of this invitation.

  • Joint Return means any Return of a member of the Parent Group or the SpinCo Group that is not a Separate Return.

  • SAP Group means SAP Parent and any of its Associated Companies.

  • Company Business means the business of the Company and its Subsidiaries as presently conducted.

  • Carryback means any net operating loss, net capital loss, excess tax credit, or other similar Tax item which may or must be carried from one Tax Period to another Tax Period under the Code or other applicable Tax Law.

  • minority business enterprise means any small contractor or supplier of materials fifty-one percent or more of the capital stock, if any, or assets of which is owned by a person or persons: (1) who are active in the daily affairs of the enterprise, (2) who have the power to direct the management and policies of the enterprise, and (3) who are members of a minority, as such term is defined in subsection (a) of Connecticut General Statutes § 32-9n; and

  • SpinCo Assets shall have the meaning set forth in Section 2.2(a).