Look-Through Rule definition

Look-Through Rule means the provisions of paragraph (a)(2) of the Plan Asset Regulation.
Sample 1

Examples of Look-Through Rule in a sentence

  • However, in determining the extent to which P’s interest expense is subject to the section 163(j) limitation, S1 may not look through the stock of S2 for purposes of allocating P’s basis in its S1 stock between excepted and non-excepted trades or businesses.Several commenters objected to the Limited Look-Through Rule.

  • In most cases, the Look-Through Rule would then apply where the parent entity owns an equity security of a subsidiary entity representing more than 10 percent of the subsidiary entity’s “equity value”.

  • As proposed, the Look-Through Rule applies to an amount that has become “payable” in respect of a security that is NPP.

  • The source of the foreign exchange gain realized by the REIT is unclear in these circumstances and will depend on the interaction between the Look-Through Rule and proposed subsection 122.1(1.3) – the gain may be a dividend or rent from foreign real property.Recommendation:We recommend that the application of proposed subsection 122.1(1.3) to tiered structures be clarified.

  • To the extent that real or immoveable property situated in a country other than Canada produces rent from real or immoveable property, proposed section 122.1(1.3) should specifically characterize any such foreign exchange gains as rent from real or immoveable property (assuming the Look-Through Rule is expanded to foreign entities in the manner suggested above, the interaction between proposed 122.1(1.3) and the Look-Through Rule would need to be considered).

  • One commenter stated that the Limited Look-Through Rule should not be finalized becauseit would penalize taxpayers that incur debt at the holding company level but hold excepted trade or business assets through tiers of non-consolidated subsidiaries (such as CFCs) for non-tax reasons.

  • In circumstances where a REIT holds a liability of a subsidiary entity that is NPP but does not have a significant equity investment in that entity, the REIT would often not have the ability to obtain information from the subsidiary entity necessary to determine the underlying revenue source for purposes of applying the Look-Through Rule.

  • The Look-Through Rule replaces and broadens the scope of the current re-characterization rule in paragraph (a)(iii) of “rent from real or immoveable property”, which generally was limited to distributions of rental income from a trust.

  • However, as a result of the proposed Look-Through Rule, dividends from an internal management corporation generally would be re-characterized as revenue from the management entity’s particular source (i.e., revenue from a management business).

  • More specifically, we recommend that the application of Look-Through Rule apply to securities of a subsidiary entity that are NPP (including liabilities) but only in situations where the parent entity holds a “security” of the subsidiary entity that satisfies any of paragraphs (a) to (c) of “equity” and that security is in and of itself NPP.

Related to Look-Through Rule

  • Look-Through Entity means a Person that is either (i) described in Section 401(a) of the Code as provided under Section 856(h)(3) of the Code or (ii) registered under the Investment Company Act of 1940.

  • Flow-Through Entity means an entity that is treated as a partnership not taxable as a corporation, a grantor trust or a disregarded entity for U.S. federal income tax purposes or subject to treatment on a comparable basis for purposes of state, local or foreign tax law.

  • Pass-through entity means a partnership not treated as an association taxable as a C corporation for federal income tax purposes, a limited liability company not treated as an association taxable as a C corporation for federal income tax purposes, an S corporation, or any other class of entity from which the income or profits of the entity are given pass-through treatment for federal income tax purposes. "Pass-through entity" does not include a trust, estate, grantor of a grantor trust, or disregarded entity.

  • Fixed Pass-Through Rate Floating Pass-Through Rate" "Guaranteed Investment Contract"

  • Class G Pass-Through Rate For any Distribution Date, a per annum rate equal to the WAC Rate for such Distribution Date.

  • Xxxxxxx Rule means Section 13 of the U.S. Bank Holding Company Act of 1956, as amended, and the applicable rules and regulations thereunder.

  • Special Pass-Through Entity means a grantor trust, S corporation, or partnership (as determined, in each case, for Federal income tax purposes) where more than 50% of the value of any beneficial owner’s interest in such pass through entity is attributable to the pass-through entity’s interest in the Retained Note.

  • Pass-Through Margin With respect to each Class of Offered Certificates (except as set forth in the following sentence), the following percentages: Class A-1 Certificates, 0.1250%; Class A-2a Certificates, 0.0700%; Class A-2b Certificates, 0.1000%; Class A-2c Certificates, 0.1400%; Class A-2d Certificates, 0.2500%; Class M-1 Certificates, 0.3000%; Class M-2 Certificates, 0.3300%; Class M-3 Certificates, 0.3400%; Class M-4 Certificates, 0.4000%; Class M-5 Certificates, 0.4300%; Class M-6 Certificates, 0.4700%; Class B-1 Certificates, 0.9700%; Class B-2 Certificates, 1.1000%; and Class B-3 Certificates, 1.9500%. On the first Distribution Date after the Optional Termination Date, the Pass-Through Margins shall increase to: Class A-1 Certificates, 0.2500%; Class A-2a Certificates, 0.1400%; Class A-2b Certificates, 0.2000%; Class A-2c Certificates, 0.2800%; Class A-2d Certificates, 0.5000%; Class M-1 Certificates, 0.4500%; Class M-2 Certificates, 0.4950%; Class M-3 Certificates, 0.5100%; Class M-4 Certificates, 0.6000%; Class M-5 Certificates, 0.6450%; Class M-6 Certificates, 0.7050%; Class B-1 Certificates, 1.4550%; Class B-2 Certificates, 1.6500%; and Class B-3 Certificates, 2.9250%.

  • Pass-Through Rate For any interest bearing Class of Certificates or Component, the per annum rate set forth or calculated in the manner described in the Preliminary Statement.

  • Class H Pass-Through Rate With respect to any Distribution Date, a per annum rate equal to the Weighted Average Net Mortgage Rate.

  • Class D Pass-Through Rate For any Distribution Date, a per annum rate equal to 2.00000%.

  • Share of Additional Book Basis Derivative Items means in connection with any allocation of Additional Book Basis Derivative Items for any taxable period, (i) with respect to the Unitholders holding Common Units, Class B Units or Subordinated Units, the amount that bears the same ratio to such Additional Book Basis Derivative Items as the Unitholders’ Remaining Net Positive Adjustments as of the end of such period bears to the Aggregate Remaining Net Positive Adjustments as of that time, (ii) with respect to the General Partner (as holder of the General Partner Units), the amount that bears the same ratio to such Additional Book Basis Derivative Items as the General Partner’s Remaining Net Positive Adjustments as of the end of such period bears to the Aggregate Remaining Net Positive Adjustment as of that time, and (iii) with respect to the Partners holding Incentive Distribution Rights, the amount that bears the same ratio to such Additional Book Basis Derivative Items as the Remaining Net Positive Adjustments of the Partners holding the Incentive Distribution Rights as of the end of such period bears to the Aggregate Remaining Net Positive Adjustments as of that time.

  • Additional Book Basis Derivative Items means any Book Basis Derivative Items that are computed with reference to Additional Book Basis. To the extent that the Additional Book Basis attributable to all of the Partnership’s Adjusted Property as of the beginning of any taxable period exceeds the Aggregate Remaining Net Positive Adjustments as of the beginning of such period (the “Excess Additional Book Basis”), the Additional Book Basis Derivative Items for such period shall be reduced by the amount that bears the same ratio to the amount of Additional Book Basis Derivative Items determined without regard to this sentence as the Excess Additional Book Basis bears to the Additional Book Basis as of the beginning of such period.

  • Class B Pass-Through Rate As to any Distribution Date, 6.750% per annum.

  • Look-Through Ownership Limit means, for any Look-Through Entity, a number of the Outstanding shares of Class B Preferred Stock of the Corporation having an Aggregate Value not in excess of the excess of (x) 15% of the Aggregate Value of all Outstanding shares of Equity Stock over (y) by the Aggregate Value of all shares of Equity Stock other than Class B Preferred Stock that are Beneficially Owned by the Look-Through Entity.

  • HIPAA Privacy Rule as defined in 45 CFR Part 164, Subparts A and E.

  • Class X-D Pass-Through Rate For any Distribution Date, the weighted average of the Class X Strip Rates for the Class X-D Components for such Distribution Date (weighted on the basis of the respective Component Notional Amounts of such Components outstanding immediately prior to such Distribution Date).

  • Regulation RR means Regulation RR (Credit Risk Retention) promulgated by the Securities and Exchange Commission to implement the credit risk retention requirements of Section 15G of the Securities Exchange Act.

  • Class F Pass-Through Rate With respect to any Distribution Date, a per annum rate equal to the Weighted Average Net Mortgage Rate.

  • Class A-S Pass-Through Rate For any Distribution Date, a per annum rate equal to 3.4150%.

  • Class A Fixed Pass-Through Rate As to any Distribution Date, the rate per annum set forth in Section 11.01.

  • Regulation CF means Regulation Crowdfunding promulgated under the Securities Act.