Non-Stepped Up Tax Basis definition

Non-Stepped Up Tax Basis means, with respect to any Reference Asset at any time, the Tax basis that such asset would have had at such time if no Basis Adjustments had been made.

Non-Stepped Up Tax Basis means, with respect to any IPO Date Asset at any time, the Tax basis that such asset would have had at such time if no Pre-IPO Basis Adjustments had been made.

Non-Stepped Up Tax Basis means, with respect to any Reference Asset at any time, (a) if the Reference Asset was transferred in the IPCo Transfer (or any asset that is “substituted basis property” under Section 7701(a)(42) of the Code with respect thereto), a Tax basis of zero dollars and (b) with respect to any other Reference Asset, the Tax basis that such Reference Asset would have had at such time if there had been no Basis Adjustment with respect to such Reference Asset.

Examples of Non-Stepped Up Tax Basis in a sentence

• The Actual Tax Liability for each Taxable Year shall be calculated by assuming that each Adjusted Asset had a tax basis equal to its Non-Stepped Up Tax Basis as of immediately before each applicable Exchange (for purposes of measuring the Basis Adjustment resulting from such Exchange).

• It is the intention of the parties for the Charter Member to pay A/N 50% of the additional Covered Taxes that the Charter Group would have been required to pay on Tax Returns that have actually been filed had those Tax Returns been computed by reference to Non-Stepped Up Tax Basis for the Exchange Assets and excluding any deductions attributable to Imputed Interest and this Agreement shall be interpreted in accordance with such intention.

• Accordingly, any adjustment to Tax basis allocated to items of deferred revenue and any adjustments pursuant to Section 481 of the Code shall be appropriately taken into account in the calculations of Exchange Basis, Non- Exchange Basis, Basis Adjustments and Non-Stepped Up Tax Basis.

More Definitions of Non-Stepped Up Tax Basis

Non-Stepped Up Tax Basis in respect of any Exchanging TRA Member means, with respect to any asset at any time, the Tax basis that such asset would have had at such time if no Basis Adjustment had been made in respect of such Exchanging TRA Member.

Non-Stepped Up Tax Basis means, with respect to any asset at any time, the Tax basis that such asset would have had at such time if no Basis Adjustments had been made.

Non-Stepped Up Tax Basis means, with respect to any Reference Asset, the Tax basis that such asset would have had at the time of the Exchange if no Basis Adjustments had been made.

Non-Stepped Up Tax Basis means in respect of an LLC Unit Holder, with respect to any Reference Asset at any time, the Tax basis that such asset would have had at such time if no Basis Adjustments had been made in respect of such LLC Unit Holder.

Non-Stepped Up Tax Basis in respect of any Exchanging Member means, with respect to any asset at any time, the Tax basis that such asset would have had at such time if no Basis Adjustment had been made in respect of such Exchanging Member.

Non-Stepped Up Tax Basis means, with respect to any Reference Asset at the time of the Reorganization that is depreciable or amortizable for United States federal income tax purposes, the Tax basis that such Reference Asset would have had if the Blocker Transferred Basis at the time of the Reorganization was equal to zero.

Non-Stepped Up Tax Basis means the Tax basis that the assets held directly or indirectly by the Corporation (or any other member of the consolidated, combined or unitary group of which the Corporation is a member) would have had if no Boot Basis Adjustments had been made.