Examples of Imputed Interest in a sentence
Tax Benefits Payments paid to any LP TRA Holder shall be treated (i) if such payment is being made before an Exchange, as a guaranteed payment described in section 707(c) of the Code, and (ii) if such payment is being made following an Exchange by such LP TRA Holder (or its predecessor in interest), in part as Imputed Interest and in part as additional purchase price for the Interests.
Tax Benefit Payments (other than amounts accounted for as Imputed Interest) arising as a result of an Exchange or a payment in respect of the Foundation Assets shall be treated as upward purchase price adjustments that give rise to further Tax Assets that shall be incorporated into the current year calculation and into future year calculations, as appropriate.
The Actual Tax Liability shall take into account the deduction of the portion of each Tax Benefit Payment (if any) that is accounted for as Imputed Interest under the Code due to the characterization of such Tax Benefit Payments as additional consideration payable by the Corporation for the Interests acquired in connection with an Exchange or the Foundation Asset Purchase, as applicable.
Tax Benefit Payments paid to the Foundation shall be treated in part as Imputed Interest and in part as additional purchase price for the Foundation Assets.