Minimum Tax Distribution definition

Minimum Tax Distribution means an amount per Membership Unit (other than Preferred Units) for each calendar quarter for each taxable year of the Company equal to the product of (i) the sum of (a) the greater of the highest marginal Federal income tax rate for such taxable year applicable to (x) individuals or (y) large, widely-held corporations and (b) the highest combined marginal state and local income tax rates for such taxable year for the state and city with the highest marginal income tax rates and (ii) the taxable income allocable to each Membership Unit for such calendar quarter as reasonably estimated by the Company.
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Minimum Tax Distribution means the distribution provided for in Section 5.2.
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Minimum Tax Distribution means, with respect to Borrower's members, an amount sufficient to permit the Members to pay their federal and state income taxes for a given taxable year on the aggregate taxable income, as adjusted by the proviso of this paragraph, allocated to such members for such tax year pursuant to the Operating Agreement, assuming for this purpose that such members are subject to the highest U.S. federal statutory marginal ordinary income tax rate then applicable for individuals; provided, however, if such members have been allocated in prior tax years losses, such losses shall first be offset against income for such tax year (to determine a net taxable income), until all such losses have been offset against income in such tax year or prior tax years, and the amount of such taxable income, less the offsetting losses, if any, shall be regarded as the amount of taxable income of such members for such tax year.
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Examples of Minimum Tax Distribution in a sentence

  • Pursuant to this Section 5.2, a ------------------------- distribution for the payment of federal, state and local Income Taxes for a Partner (a "Minimum Tax Distribution") for each applicable period shall be made to a Partner holding a Common Partnership Interest in an amount equal to the U.S. Taxes Due for such Partner, less Cumulative Minimum Tax Distributions.

  • In the event the reductions under Sections 5.2(b) or 5.2(c) reduce a Minimum Tax Distribution distributable to a Partner to an amount less than such Partner's U.S. Taxes Due, the Executive Committee may, in its discretion, unanimously agree to decrease the reductions to be made under Sections 5.2(b) or 5.2(c) in an amount necessary for a Partner to receive a distribution with respect to Minimum Tax Distributions in an amount needed to pay such Partner's U.S. Taxes Due.

  • Notwithstanding the reductions required under Sections 5.2(b) or 5.2(c), no recharacterization of a Minimum Tax Distribution Carryforward under Section 5.2(b) as a Minimum Tax distribution or other distributions under Section 5.2(c) as Minimum Tax Distributions shall have the effect of recharacterizing such reductions as "Section 704(c) Distributions" (as defined below).


More Definitions of Minimum Tax Distribution

Minimum Tax Distribution means, with respect to any Member for any Taxable Year, the excess, if any, of (a) the Cumulative Assumed Tax Liability of such Member as of such Taxable Year, over (b) the sum of (i) the amount of distributions made to such Member pursuant to Section 4.01(a) during such Taxable Year and all prior Taxable Years, plus (ii) the amount of distributions made to such Member pursuant to Section 4.01(b) with respect to all prior Taxable Years.
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Related to Minimum Tax Distribution

  • Tax Distribution has the meaning set forth in Section 4.4.

  • Tax Distribution Amount means, with respect to a Member’s Units, whichever of the following applies with respect to the applicable Tax Distribution, in each case in amount not less than zero:

  • Tax Distribution Date has the meaning set forth in Section 4.01(b)(i).

  • Tax Distributions has the meaning set forth in Section 4.01(b)(i).

  • Permitted Tax Distribution for any fiscal year means any payments in compliance with clause (6) of the second paragraph under Section 4.03.

  • Permitted Tax Distributions means, with respect to a Credit Party so long as it is taxable as a partnership or disregarded entity for United States federal income tax purposes, tax distributions to the owners of Equity Interests in such Credit Party (its “shareholders”) in an aggregate amount that does not exceed, with respect to any period, an amount equal to (a) the product of (i) the Applicable Tax Percentage, multiplied by (ii) such Credit Party’s federal taxable income, minus (b) to the extent not previously taken into account, any income tax benefit attributable to such Credit Party which could be utilized by its shareholders, in the current or any prior year, or portion thereof, from and after the Closing Date (including any tax losses or tax credits), computed at the Applicable Tax Percentage of the year that such benefit is taken into account for purposes of this computation; provided, however, that the computation of distributions under this definition shall also take into account (x) the deductibility of state and local taxes for federal income tax purposes and (y) any difference in the Applicable Tax Percentage resulting from the nature of the taxable income (such as capital gain as opposed to ordinary income, if applicable; provided, further, that, in the event (x) the actual distribution to a shareholder made pursuant to this definition exceeds the actual income tax liability of any such shareholder due to such Credit Party’s status as a partnership or “disregarded entity” for U.S. federal or other applicable income tax purposes, or (y) if such Credit Party is a subchapter C corporation, such Credit Party would be entitled to a refund of income taxes previously paid as a result of a tax loss during a year in which such Credit Party is a partnership or “disregarded entity” for U.S. federal or other applicable income tax purposes, then, such shareholder shall repay such Credit Party the amount of such excess or refund, as the case may be, no later than the date the annual tax return must be filed by such Credit Party (without giving effect to any filing extensions) and, in the event such amounts are not repaid in a timely manner by any, then such Credit Party shall not pay or make any distribution with respect to, or purchase, redeem or retire, any Equity Interest of such Credit Party held or Controlled by, directly or indirectly, such shareholder until such payment has been made.

  • Cash Flow Distribution Amount As to any calendar month, the aggregate amount of principal distributable in respect of the Mortgage Securities in such calendar month.

  • Post-Distribution Tax Period means a Tax year beginning and ending after the Distribution Date.

  • Net After Tax Amount means the amount of any Parachute Payments or Capped Payments, as applicable, net of taxes imposed under Code Sections 1, 3101 (b) and 4999 and any State or local income taxes applicable to the Executive on the date of payment. The determination of the Net After Tax Amount shall be made using the highest combined effective rate imposed by the foregoing taxes on income of the same character as the Parachute Payments or Capped Payments, as applicable, in effect on the date of payment.

  • Quarterly Distribution means with respect to each Distribution Date, the distribution to be made to the Holders of the Up-MACRO Holding Shares that are Outstanding on the Distribution Date pursuant to priority sixth of Section 5.2(a), which shall consist of the cash on deposit in the Up-MACRO Holding Trust after it makes or receives a payment under the Income Distribution Agreement and makes all other payments or investments in Eligible Treasuries that it is required to make pursuant to such Section 5.2(a).

  • After Tax Amount means the amount of the Aggregate Payments less all federal, state, and local income, excise and employment taxes imposed on the Executive as a result of the Executive’s receipt of the Aggregate Payments. For purposes of determining the After Tax Amount, the Executive shall be deemed to pay federal income taxes at the highest marginal rate of federal income taxation applicable to individuals for the calendar year in which the determination is to be made, and state and local income taxes at the highest marginal rates of individual taxation in each applicable state and locality, net of the maximum reduction in federal income taxes which could be obtained from deduction of such state and local taxes.

  • Tax Amount has the meaning set forth in Section 4.01(b)(i).

  • Minimum Quarterly Distribution means $0.35 per Unit per Quarter (or with respect to the period commencing on the Closing Date and ending on September 30, 2005, it means the product of $0.35 multiplied by a fraction of which the numerator is the number of days in such period and of which the denominator is 92), subject to adjustment in accordance with Section 6.6 and Section 6.9.

  • Quarterly Distribution Date means the last Business Day of the month following the end of each calendar quarter after the Effective Date; provided, however, that if the Effective Date is within 45 days of the end of a calendar quarter, the first Quarterly Distribution Date will be the last Business Day of the month following the end of the first calendar quarter after the calendar quarter in which the Effective Date falls.

  • Total Distribution Amount With respect to any Distribution Date, the sum of (i) the aggregate of the Interest Remittance Amounts for such date; (ii) the aggregate of the Principal Remittance Amounts for such date; and (iii) all Prepayment Premiums collected during the related Prepayment Period.

  • Pre-Distribution Tax Period means any taxable period (or portion thereof) that ends on or before the Distribution Date.

  • REMIC I Distribution Amount For any Distribution Date, the REMIC I Available Distribution Amount shall be distributed to the REMIC I Regular Interests and the Class R-1 Residual Interest in the following amounts and priority:

  • Pool Distribution Amount As of any Distribution Date, the funds eligible for distribution to the Holders of the Certificates on such Distribution Date, which shall be the sum of (i) all previously undistributed payments or other receipts on account of principal and interest on or in respect of the Mortgage Loans (including, without limitation, the proceeds of any repurchase of a Mortgage Loan by the Seller and any Substitution Principal Amount) received by the Master Servicer with respect to the applicable Remittance Date in the month of such Distribution Date and any Unscheduled Principal Receipts received by the Master Servicer on or prior to the Business Day preceding such Distribution Date, (ii) all Periodic Advances made by a Servicer pursuant to the related Servicing Agreement or Periodic Advances made by the Master Servicer or the Trustee pursuant to Section 3.03 and (iii) all other amounts required to be placed in the Certificate Account by the Servicer on or before the applicable Remittance Date or by the Master Servicer or the Trustee on or prior to the Distribution Date, but excluding the following:

  • Post-Distribution Period means any Taxable period (or portion thereof) beginning after the Distribution Date.

  • Extra Principal Distribution Amount As of any Distribution Date, the lesser of (x) the related Total Monthly Excess Spread for such Distribution Date and (y) the related Subordination Deficiency for such Distribution Date.

  • maximum council tax reduction amount means the amount determined in accordance with paragraph 29;

  • Profit Distribution Date means the date on which the Management Company decides to distribute the profits (if any).

  • Class B-6 Distribution Amount As to any Distribution Date, any amount distributable to the Holders of the Class B-6 Certificates pursuant to Paragraphs twentieth, twenty-first and twenty-second of Section 4.01(a).

  • Current Distribution Date means a Distribution Date specified as a reference date for calculating the Expected Distributions with respect to the Certificates of any Trust as of such Distribution Date.

  • REMIC IV Distribution Amount shall not cause a reduction in the Class Principal Balances of any of the Classes of REMIC IV Regular Interests; and

  • Relevant Distribution Date With respect to (a) any Significant Obligor with respect to the Trust, the Distribution Date, and (b) any Significant Obligor with respect to an Other Securitization Trust, the “Distribution Date” (or an analogous concept) under the related Other Pooling and Servicing Agreement.