Mark-to-Market Election definition

Mark-to-Market Election means a mark-to-market election under Section 1296 of the U.S. Code.
Sample 1Sample 2Sample 3
Mark-to-Market Election means a mark-to-market election made by a U.S. Holder under section 1296 of the Code.
Sample 1
Mark-to-Market Election means an election by a U.S. Holder under Section 1296 of the Code.
Sample 1

Examples of Mark-to-Market Election in a sentence

  • Modification of Passive Foreign Investment Com- pany Provisions to Eliminate Overlap With Sub- part F, to allow Mark-to-Market Election, and to Require Measurement Based on Value for PFIC Asset Test (secs.

  • The Mark-to-Market Election provides an alternative for these funds and their shareholders to achieve tax results that are consistent with the economics of the currency hedging.

  • We note that our phrasing here intentionally refers to the straddle rules as being inapplicable where a taxpayer (i) makes the Mark-to-Market Election and (ii) holds one or more section 988 transactions that diminish currency risk on or more other section 988 transactions.

  • That the Mark-to-Market Election can be applied with respect to the full amount of section 988 gain or loss on all section 988 transactions held during or following the taxable year in which the Mark-to-Market Election is made (the “Election Year”).In addition, we, like other taxpayers, understand the “Applicability Dates” section of the preamble to the proposed regulations to permit taxpayers to make the Mark-to-Market Election for taxable years ending on or after December 19, 2017.

  • First, the Mark-to-Market Election could apply only to section 988 transactions entered into during or following the Election Year, in which case the Pre-Election Section 988 Transactions would not be subject to the election.

  • Modification of Passive Foreign Investment Company Provisions to Eliminate Overlap With Subpart F, to Allow Mark-to-Market Election, and to Require Measurement Based on Value for PFIC Asset Test (secs.

  • Accordingly, the Mark-to-Market Election would apply to the full amount of section 988 gain or loss on all section 988 transactions held during or following the Election Year (including section 988 gain or loss attributable to the period prior to the Election Year on Pre- Election Section 988 Transactions).

  • Therefore, we do not believe that this general policy against bifurcation should be of concern to the government in confirming that the straddle rules do not apply as described above.proposed regulations do not address whether or how the Mark-to-Market Election applies to these transactions.Three approaches seem possible.

  • Accordingly, some mutual funds may make the Mark-to-Market Election for taxable years ending December 31, 2017 or thereafter.

  • We recommend this wording rather than stating that the straddle rules are inapplicable where a taxpayer holds one or more section 988 transactions subject to the Mark-to-Market Election that diminish currency risk on one or more other section 988 transactions subject to the Mark-to-Market Election.Under Prop.


More Definitions of Mark-to-Market Election

Mark-to-Market Election means the election described in Section 1296 of the Code;
Sample 1

Related to Mark-to-Market Election

  • Mark-to-market means the valuation of positions at readily available close out prices that are sourced independently, including exchange prices, screen prices or quotes from several independent reputable brokers. When using mark-to-market, the assets of the Money Market Funds shall be valued at the more prudent side of bid and offer unless the assets can be closed out at mid- market.

  • Net Mark-to-Market Exposure of any Person shall mean, as of any date of determination with respect to any Hedging Obligation, the excess (if any) of all unrealized losses over all unrealized profits of such Person arising from such Hedging Obligation. “Unrealized losses” shall mean the fair market value of the cost to such Person of replacing the Hedging Transaction giving rise to such Hedging Obligation as of the date of determination (assuming such Hedging Transaction were to be terminated as of that date), and “unrealized profits” shall mean the fair market value of the gain to such Person of replacing such Hedging Transaction as of the date of determination (assuming such Hedging Transaction were to be terminated as of that date).

  • Net Xxxx-to-Market Exposure of a Person means, as of any date of determination, the excess (if any) of all unrealized losses over all unrealized profits of such Person arising from Rate Management Transactions. “Unrealized losses” means the fair market value of the cost to such Person of replacing such Rate Management Transaction as of the date of determination (assuming the Rate Management Transaction were to be terminated as of that date), and “unrealized profits” means the fair market value of the gain to such Person of replacing such Rate Management Transaction as of the date of determination (assuming such Rate Management Transaction were to be terminated as of that date).

  • IDR Reset Election has the meaning given such term in Section 5.11(a).

  • Total effective dose equivalent (TEDE) means the sum of the deep dose equivalent for external exposures and the committed effective dose equivalent for internal exposures.

  • Call Equivalent Position shall have the meaning set forth in Rule 16a-1(b) under the Exchange Act.

  • S&P Eligible Asset means: (1) cash (excluding any cash irrevocably deposited by the Fund for the payment of any liabilities within the meaning of MTP Basic Maintenance Amount), (2) Receivables for Municipal Obligations Sold, (3) S&P Hedging Transactions or (4) a Municipal Obligation (including Inverse Floater as defined below) owned by the Fund that (A) is interest bearing and pays interest at least semi-annually; (B) is payable with respect to principal and interest in U.S. Dollars; (C) is not subject to a covered call or put option written by the Fund; (D) except for Inverse Floaters, is not part of a private placement of Municipal Obligations; and (E) except for Inverse Floaters, is part of an issue of Municipal Obligations with an original issue size of at least $10 million. Any Municipal Obligation that is a part of an original issue size of less than $10 million must carry a rating of at least “AA” by S&P or “AAA” by Moody’s, Fitch or another nationally recognized statistical rating organization. Notwithstanding the foregoing limitations:

  • Floating Profit/Loss in a CFD shall mean current profit/loss on Open Positions calculated at the current Quotes (added any commissions or fees if applicable).

  • Total Intrinsic Loss Estimate means the sum of the SF1-4 Intrinsic Loss Estimate in the Single Family Shared-Loss Agreement, and the Commercial Intrinsic Loss Estimate in the Commercial Shared-Loss Agreement, expressed in dollars.

  • Qualifying loss means the amount of compensation attributable to a taxpayer’s nonqualified deferred compensation plan, less the receipt of money and property attributable to distributions from the nonqualified deferred compensation plan. Full loss is sustained if no distribution of money and property is made by the nonqualified deferred compensation plan. The taxpayer sustains a qualifying loss only in the taxable year in which the taxpayer receives the final distribution of money and property pursuant to that nonqualified deferred compensation plan.

  • LCT Election has the meaning assigned to such term in Section 1.06.

  • adjusted underlying revenue means total income other than:

  • Adjusted Total Assets means, for any Person, the sum of:

  • Consolidated Total Tangible Assets means, as of any date, the Consolidated Total Assets as of such date, less all goodwill and intangible assets determined in accordance with GAAP included in such Consolidated Total Assets.

  • 5-year Mid-Swap Rate Quotations means the arithmetic mean of the bid and offered rates for the annual fixed leg (calculated on a 30/360 day count basis) of a fixed-for-floating euro interest rate swap transaction which:

  • Fitch Eligible Assets means the assets of the Company set forth in the Fitch Guidelines as eligible for inclusion in calculating the Agency Discounted Value of the Company’s assets in connection with Fitch’s ratings then assigned on the MRP Shares.

  • DBRS Equivalent Rating means, with respect to any date and any Person with respect to whom DBRS does not maintain a public Relevant DBRS Rating as of such date,

  • Put Equivalent Position shall have the meaning set forth in Rule 16a-1(h) under the Exchange Act.

  • Qualifying Income Gross income that is described in Section 856(c)(2) or 856(c)(3) of the Code.

  • Adjusted Total turnover means the turnover in a State or a Union territory, as defined under sub-section (112) of section 2, excluding the value of exempt supplies other than zero-rated supplies, during the relevant period;

  • Unadjusted Benchmark Replacement means the applicable Benchmark Replacement excluding the related Benchmark Replacement Adjustment.

  • Cumulative Net Loss Test With respect to any Payment Date, a test that will be satisfied if the Cumulative Net Loss Percentage does not exceed the applicable percentage indicated below: Payment Date occurring in the period Percentage February 2018 to January 2019 0.10% February 2019 to January 2020 0.20% February 2020 to January 2021 0.30% February 2021 to January 2022 0.40% February 2022 to January 2023 0.50% February 2023 to January 2024 0.60% February 2024 to January 2025 0.70% February 2025 to January 2026 0.80% February 2026 to January 2027 0.90% February 2027 to January 2028 1.00% February 2028 to January 2029 1.10% February 2029 to January 2030 1.20% February 2030 and thereafter 1.30% Current Accrual Rate: With respect to each Payment Date and any Reference Obligation, the lesser of (i) the related current Accounting Net Yield; and (ii) the related current mortgage rate thereon (as adjusted for any modifications) minus 0.35%.

  • Derivatives Termination Value means, in respect of any one or more Derivatives Contracts, after taking into account the effect of any legally enforceable netting agreement relating to such Derivatives Contracts, (a) for any date on or after the date such Derivatives Contracts have been closed out and termination value(s) determined in accordance therewith, such termination value(s), and (b) for any date prior to the date referenced in clause (a) the amount(s) determined as the xxxx-to-market value(s) for such Derivatives Contracts, as determined based upon one or more mid-market or other readily available quotations provided by any recognized dealer in such Derivatives Contracts (which may include the Agent or any Lender).

  • 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.

  • Specified Transaction will have the meaning specified in Section 14 of this Agreement.

  • Equivalent position means employment in an equivalent position, in relation to the employee’s previous position, that is:  generally similar in role, duties and status; and  requires similar qualifications, training, skills and experience but may have a different title/or unit allocation; and • is in the same general locality; and • is on terms and conditions of employment that are no less favourable than those that applied to the employee immediately before the offer of employment.