New Partnership Audit Rules definition

New Partnership Audit Rules means the provisions of subchapter C of chapter 63 of subtitle F of the Code (i.e., Sections 6221 through 6241 of the Code), as in effect for tax years beginning after December 31, 2017, and any Treasury Regulations promulgated thereunder.
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New Partnership Audit Rules has the meaning set forth in Section 6.6.
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Examples of New Partnership Audit Rules in a sentence

  • To the extent that the Partnership Representative does not make an election to apply the alternative method provided by Section 6226 of the Code (or any analogous provision of state or local tax law), the Partnership Representative shall have the authority and discretion to determine the portion of any imputed underpayment (within the meaning of the New Partnership Audit Rules) allocable to each Member.

  • Each Member hereby agrees to indemnify and hold harmless the Company, the other Members, the Partnership Representative and the Manager from and against any liability (including any liability for partnership-level taxes imposed with respect to the New Partnership Audit Rules) with respect to income attributable to or distributions or other payment to such Member.

  • Each Member agrees that any payment by the Company of a partnership-level tax imposed with respect to the New Partnership Audit Rules shall be treated as paid with respect to such Member.

  • New Partnership Audit Rules ProjectThe Bipartisan Budget Act of 2015 (Pub.

  • Smith, Norton Rose Fulbright • Taxation by Executive Fiat: IRS Launches Renewed Attack on Valuation of Family Businesses – A Seismic Shift For Estate and Gift TaxationsNorm Lofgren, Gray Reed & McGraw, P.C. • Electing Into New Partnership Audit Rules Chester Grudzinski, Kelly, Hart & Hallman LLP Jason Hendrix, Kelly, Hart & Hallman LLP • Preparing for a Partial Plan Termination – Considerations and Consequences Jessica Stricklin, Baker Botts L.L.P. • Estate of Clara M.

  • Understanding the New Partnership Audit Rules ..........................

  • Each Member hereby agrees to indemnify and hold harmless the Company, the other Members, the Partnership Representative and the Manager from and against any liability (including any liability for partnership level taxes imposed with respect to the New Partnership Audit Rules) with respect to income attributable to or distributions or other payment to such Member.

  • If the Company comes to be subject to the New Partnership Audit Rules for any period the Company will, with respect to any “final partnership adjustment” (as such term is defined for purposes of Section 6226(a) of the Code (as revised to reflect the New Partnership Audit Rules) or any successor provision), make the election provided for in Section 6226(a) of the Code (as revised to reflect the New Partnership Audit Rules) or any successor provision).

  • Furthermore, all the materials used for this research have been acknowledged.

  • If the Company is otherwise eligible, the Company shall, if approved by the Required Majority, file a timely annual election in connection with the filing of its tax return to have the Company opt out of the New Partnership Audit Rules in the manner provided in Code § 6221(b).

Related to New Partnership Audit Rules

  • BBA Partnership Audit Rules means Sections 6221 through 6241 of the Code, and any regulations promulgated or proposed under any such Sections and any administrative guidance with respect thereto.

  • Partnership Tax Audit Rules means Sections 6221 through 6241 of the Code, as amended by the Bipartisan Budget Act of 2015, together with any guidance issued thereunder or successor provisions and any similar provision of state or local tax laws.

  • MLP Partnership Agreement means the Amended and Restated Agreement of Limited Partnership of the MLP, as amended or restated from time to time.

  • Partnership Act means the Delaware Revised Uniform Limited Partnership Act, 6 Del. C. §§ 17-101, et seq., as it may be amended from time to time, and any successor to such statute.

  • SIFT Rules means the provisions of the Tax Act, including those contained in sections 104, 122 and 122.1 of the Tax Act, which apply to the taxation of a “specified investment flow through trust” and its unitholders.

  • Operating Partnership Agreement means the Limited Partnership Agreement of the Operating Partnership, as amended from time to time.

  • Limited Partnership Agreement means the Amended and Restated Agreement of Limited Partnership of the Partnership dated as of March 1, 2017, as amended, supplemented or restated from time to time.

  • Partnership at will means a partnership in which the partners have not agreed to remain partners until the expiration of a definite term or the completion of a particular undertaking.

  • Public-private partnership agreement means an agreement

  • Borrower Partnership Agreement means the Limited Partnership Agreement of the Borrower dated as of January 17, 2014 as such agreement may be amended, restated, modified or supplemented from time to time with the consent of the Administrative Agent or as permitted under Section 10.10.

  • General Partner means the general partner of the Partnership.

  • Partnership Agreement means the Amended and Restated Agreement of Limited Partnership of the Partnership, dated as of May 28, 2014, as amended, restated and supplemented from time to time hereafter.

  • Tax Matters Partner has the meaning set forth in Section 5.08.

  • General partnership means an organization formed under chapters 45-13 through 45-21.

  • 1940 Act Rules and Regulations means the rules and regulations of the Commission under the 1940 Act.

  • Delaware LP Act means the Delaware Revised Uniform Limited Partnership Act.

  • Advisers Act Rules and Regulations means the rules and regulations of the Commission under the Advisers Act.

  • Organizational Limited Partner means Xxxxx X. Xxxxxxx.

  • SAP Partner Code of Conduct means SAP Group’s global policy document that provides a set of informative guidelines to enable partners to comply with good business practices which is published on SAP’s partner-dedicated website.

  • Original Partnership Agreement has the meaning set forth in the recitals to this Agreement.

  • Apprenticeship Agreement means a written agreement between the Company and the person employed as an apprentice, which agreement or indenture shall be reviewed by the Joint Apprenticeship Committee and registered with the Registration Agencies.

  • Certificate of Limited Partnership means the Certificate of Limited Partnership of the Partnership filed with the Secretary of State of the State of Delaware as referenced in Section 7.2, as such Certificate of Limited Partnership may be amended, supplemented or restated from time to time.

  • Foreign limited liability limited partnership means a foreign limited partnership whose general partners have limited liability for the obligations of the foreign limited partnership under a provision similar to section 488.404, subsection 3.

  • PPB Rules means the rules of the Procurement Policy Board as set forth in Title 9 of the Rules of the City of New York (“RCNY”), § 1-01 et seq.

  • Company LLC Agreement means the Second Amended and Restated Limited Liability Company Agreement of the Company, dated as of May 25, 2011, as amended from time to time.

  • Public-private partnership means an arrangement or agreement, occurring on or after January 1, 2017, between a procurement unit and one or more contractors to provide for a public need through the development or operation of a project in which the contractor or