Full Taxpayer definition

Full Taxpayer means the assumption that each relevant member of the Ironwood Group (a) is subject to the highest marginal regular statutory income Tax rate, and (b) will not utilize any Tax Attribute other than a Tax Attribute arising from the adjustment at issue.
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Full Taxpayer means the assumption that each relevant member of the bluebird Group (a) is subject to the highest marginal regular statutory income Tax rate applicable to corporations, and (b) will not utilize any Tax Attribute other than a Tax Attribute arising from the adjustment at issue.
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Full Taxpayer means the assumption that each relevant member of the relevant Group (a) is subject to the highest marginal regular statutory income Tax rate, and (b) will not utilize any Tax Attribute other than a Tax Attribute arising from the adjustment at issue.
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Examples of Full Taxpayer in a sentence

  • For purposes of determining the amount of Taxes for which the Distributing Group is, or is reasonably be expected to be, liable as a result of an adjustment pursuant to a Final Determination, the Distributing Group shall be deemed (i) not to utilize any Tax Attributes available to the Distributing Group and (ii) to be a Distributing Full Taxpayer.

  • For purposes of determining whether (and when) an adjustment to any Taxes for which a member of the Parent Group is liable hereunder is expected to result in a Tax Benefit for SpinCo, the SpinCo Group shall be deemed to be a SpinCo Full Taxpayer.

  • In the case of each of the items described in 2.03(a) such amounts to be calculated on the basis that Post or such Post Group member or Affiliate is a Post Full Taxpayer.

  • A “Correlative Detriment” is an increase in a Tax of a Party (or its Affiliates) that occurs as a result of the Tax position that is the basis for a claim for Refund by the Claiming Party or for a Final Determination, utilizing the assumptions set forth in the description of HP Full Taxpayer or Enterprise Full Taxpayer, as the case may be.

  • Enterprise shall be liable for, and shall indemnify and hold harmless the HP Group from and against any liability for, Pre-Distribution Period Taxes which are allocated to Enterprise under this Section 2, with such amounts to be calculated on the basis that each member of the HP Group is an HP Full Taxpayer.

  • For purposes of determining the amount of Taxes for which the Ralcorp Group is, or is reasonably expected to be, liable as a result of an adjustment pursuant to a Final Determination, the Ralcorp Group shall be deemed (i) not to utilize any Tax Attributes available to the Ralcorp Group and (ii) to be a Ralcorp Full Taxpayer.

  • A “Correlative Detriment” is an increase in a Tax of a Company (or its Affiliates) that occurs as a result of the Tax position that is the basis for a claim for Refund by the Claiming Company or for a Final Determination, utilizing the assumptions set forth in the description of Houston Full Taxpayer or ▇▇▇▇▇▇▇ Full Taxpayer, as the case may be.

  • For the Tax Periods ending after the Deconsolidation Date, SpinCo shall be responsible for any and all State Income Taxes (calculated on the basis that SpinCo is a SpinCo Full Taxpayer) attributable to the Tax Items of the SpinCo Group (whether as a result of a Final Determination or otherwise).

  • In the case of each of the items described in this Section 2.03(b), such amounts shall be calculated on the basis that Ralcorp or such Ralcorp Group member or Affiliate is a Ralcorp Full Taxpayer.

  • HP shall be liable for, and shall indemnify and hold harmless the Enterprise Group from and against any liability for, Pre-Distribution Period Taxes which are allocated to HP under this Section 2, with such amounts to be calculated on the basis that each member of the Enterprise Group is an Enterprise Full Taxpayer.

Related to Full Taxpayer

  • U.S. Taxpayer means a Participant who, with respect to an Award, is subject to taxation under the applicable U.S. tax laws.

  • Canadian Taxpayer means a Participant that is resident of Canada for purposes of the Tax Act;

  • Taxpayer means any person subject to the tax imposed by section 5747.02 of the Revised Code or any pass-through entity that makes the election under division (D) of section 5747.08 of the Revised Code.

  • Full-time job means a job performed by an individual for 35 hours or more each week and whose income and social security taxes are withheld by 1 or more of the following:

  • Full-time position means a position of gainful employment where the number of hours worked by the employee is not less than 30 hours during any given work week.