Option Deductions definition
Examples of Option Deductions in a sentence
If a carryover or carryback of any Tax item includes a portion that is attributable to any Option Deductions and another portion that is not, such portions shall be considered to be used in accordance with the “with and without” methodology.
The Realized Tax Benefit for each Taxable Year is intended to measure the decrease in the actual liability for Taxes of the Corporate Taxpayer for such Taxable Year attributable to the Option Deductions, determined using a “with and without” methodology.
Carryovers or carrybacks of any Option Deductions shall be considered to be subject to the rules of the Code and the Treasury Regulations or the appropriate provisions of U.S. state and local income and franchise tax law, as applicable, governing the use, limitation and expiration of carryovers or carrybacks of the relevant type.
For each year, within thirty (30) days after the filing of the Sangoma CTR for the year, or if earlier, the due date of such return taking into account any applicable extensions, Buyer will deliver to Sellers’ Representative a statement of the Tax Benefit attributable to the S2S Option Deductions for such year.
The Tax Benefit will be equal to the amount by which the Tax liability shown on the IRS Form 1120 (and relevant state and local income Tax Returns) for the relevant year is less than the Tax liability that would have been shown on the IRS Form 1120 (and relevant state and local income Tax Returns) for the relevant year, had the relevant year IRS Form 1120 (and relevant state and local incme Tax Retruns) not included the S2S Option Deductions.
The Stub NOL is treated as attributable to the S2S Option Deductions to the extent the taxable loss of the Company in the Stub Period is more than the Taxable loss that the Company would have had in the Stub Period if the S2S Option Deductions had not been claimed.