Examples of New Partnership Audit Procedures in a sentence
With respect to periods governed by the New Partnership Audit Procedures, to the extent permissible under the New Partnership Audit Procedures, the Managing Member, or such person designated by the Managing Member, shall be designated as the “partnership representative” (within the meaning of Section 6223 of the New Partnership Audit Procedures (the “Partnership Representative”).
The Company may, by Board Approval, but shall not be required to, make any election pursuant to the provisions of Section 754 or 1045 of the Code, or any other election required or permitted to be made by the Company under the Code; provided, however, that no election to apply the New Partnership Audit Procedures prior to the effective date of such procedures shall be made.
To the extent permitted by applicable law, with respect to taxable years beginning after the effective date of the New Partnership Audit Procedures, the Company shall elect out of the application of the New Partnership Audit Procedures.
The General Partner shall be the “tax matters partner” of the Partnership for federal income tax purposes and the Partnership’s “partnership representative” (within the meaning of Section 6223 of the New Partnership Audit Procedures).
She is a member of the State Bar of Michigan and serves on the Business Law Section Council.Tax Matters By Eric M.N emeth New Partnership Audit Procedures and Important Tax Enforcement Changes for U.S. Passport Holders with Tax DelinquenciesUnder provisions in the Bipartisan Budget Act of 20151 (“BBA”), major changes will be forthcoming in how the IRS audits partnerships.
Put up for approval of TCC/RPC.Deliberation of the TCC Members unanimously agreed to the proposal of NERPC regarding award of SAMAST of NER.
The General Partner shall be the “tax matters partner” of the Partnership for Federal income tax purposes and its “partnership representative” within the meaning of Section 6223 of the New Partnership Audit Procedures (as applicable, the “Tax Matters Partner”).
Convents and hospitals were often active in agricultural production themselves, or entitled to tax-payments in kind, which gave them direct access to foodstuffs.
If withholding from distributions is insufficient to satisfy any amounts apportioned to any current or former Member with respect to the New Partnership Audit Procedures, such Member shall indemnify and hold harmless the Managing Member, the Tax Matters Member and the Company for such amounts, which indemnity obligation shall survive the Exchange or other Transfer of Units and the termination of this Agreement.
The General Partner shall have the right to seek to revoke any such election (including, without limitation, any election under the New Partnership Audit Procedures, Code Sections 461(h) and 754).