Imputed Underpayment definition

Imputed Underpayment means an imputed underpayment under Section 6225 of the Code, as amended by the BBA.

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Imputed Underpayment shall have the meaning set forth in Section 12.7.2(a).

Imputed Underpayment means an “imputed underpayment” within the meaning of Section 6225 of the Code or any similar provision or state, local or non-U.S. Tax Law, as applicable.

Examples of Imputed Underpayment in a sentence

• Imputed Underpayment Amounts treated as Withholding Payments also shall include any imputed underpayment within the meaning of Code Section 6225 paid (or payable) by any entity treated as a partnership for U.S. federal income tax purposes in which the Company holds (or has held) a direct or indirect interest other than through entities treated as corporations for U.S. federal income tax purposes to the extent that the Company bears the economic burden of such amounts, whether by law or agreement.

• To the extent the Company is liable for any Imputed Underpayment, the Company shall determine the liability of the Members for a share of such Imputed Underpayment, taking into account the Members’ Units and the status and actions of the Members (including those described in Code Section 6225(c)) (such share, an “Imputed Underpayment Share”).

• If the Member fails to repay the loan upon demand, the full balance of the loan shall be immediately due (including accrued but unpaid interest) and the Company shall have the right to collect the balance in any manner it determines, including by reducing future distributions to that Member; provided, however, that no Member may have any Imputed Underpayment Share treated as a loan to the extent it would violate Section 402 of the ▇▇▇▇▇▇▇▇-▇▇▇▇▇ Act of 2002.

• Imputed Underpayment Amounts also shall include any imputed underpayment within the meaning of Section 6225 of the Partnership Audit Provisions paid (or payable) by any entity treated as a partnership for U.S. federal income tax purposes in which the Company holds (or has held) a direct or indirect interest other than through entities treated as corporations for U.S. federal income tax purposes to the extent that the Company bears the economic burden of such amounts, whether by Applicable Law or contract.

• Imputed Underpayment Amounts also shall include any imputed underpayment within the meaning of Section 6225 of the Partnership Audit Rules paid (or payable) by any entity treated as a partnership for U.S. federal income tax purposes in which the Partnership holds (or has held) a direct or indirect interest other than through entities treated as corporations for U.S. federal income tax purposes to the extent that the Partnership bears the economic burden of such amounts, whether by law or contract.

More Definitions of Imputed Underpayment

Imputed Underpayment is defined in Section 4.4(d) of this ▇▇▇▇▇ ▇.

Imputed Underpayment has the meaning assigned to such term in Section 9.4(a).

Imputed Underpayment means the amount determined by applying the applicable [State] income tax rate, as determined under subsection C(4)(a), to all partnership adjustments made by a Partnership Level Audit properly apportioned to [State].

Imputed Underpayment is defined in Section 6.26(b).

Imputed Underpayment. Has the meaning set forth in Section 6225 of the Code.

Imputed Underpayment is defined in ‎Section 4.4(b) of this ‎Annex C.

Imputed Underpayment is defined in Section 5.9.1.