Partial Negative Basis definition

Partial Negative Basis means, with respect to any partially withdrawing Partner and as of any time of calculation, the amount by which the amount received (or to be received) upon such partial withdrawal as of such time plus an amount equal to any deemed distributions to such Partner for U.S. Federal income tax purposes pursuant to Section 752(b) of the Internal Revenue Code resulting from its withdrawal is less than the product of (x) its "adjusted tax basis", for U.S. Federal income tax purposes, in its interest in the Partnership as of such time and (y) a fraction, the numerator of which is the amount received (or to be received) upon such partial withdrawal plus an amount equal to any deemed distributions to such Partner for U.S. Federal income tax purposes pursuant to Section 752(b) of the Internal Revenue Code resulting from its withdrawal, and the denominator of which is the value of such partially withdrawing Partner's Capital Account(s) immediately prior to such partial withdrawal.
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Partial Negative Basis means, with respect to any Member who has only had some of its Units repurchased by the Company and as of any time of calculation, the amount by which the amount received (or to be received) upon such partial
Sample 1Sample 2
Partial Negative Basis means, with respect to any partially withdrawing Partner and as of any time of calculation, the amount by which the amount received (or to be received) upon such partial withdrawal as of such time plus an amount equal to any deemed distributions to such Partner for U.S. federal income tax purposes pursuant to Section 752 of the Internal Revenue Code resulting from its withdrawal is less than the product of (x) its “adjusted tax basis”, for U.S. federal income tax purposes, in its Interest as of such time and (y) a fraction, the numerator of which is the amount received (or to be received) plus an amount equal to any deemed distributions to such Partner for U.S. federal income tax purposes pursuant to Section 752 of the Internal Revenue Code upon such partial withdrawal, and the denominator of which is the value of such partially withdrawing Partner’s Capital Account immediately prior to such partial withdrawal plus an amount equal to any deemed distributions that would be made to such Partner for U.S. federal income tax purposes pursuant to Section 752 of the Internal Revenue Code if such Partner had completely withdrawn its Capital Account.
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More Definitions of Partial Negative Basis

Partial Negative Basis means, with respect to any partially withdrawing Partner (or Partner receiving a distribution of a portion of its Capital Account) and as of the time of calculation, the amount by which the amount received (or to be received) upon such partial withdrawal or distribution as of such time plus an amount equal to any deemed distributions to such Partner for U.S. Federal income tax purposes pursuant to Section 752(b) of the Code resulting from its withdrawal or distribution is less than the product of (x) its “adjusted tax
Sample 1
Partial Negative Basis means, with respect to any partially withdrawing Partner (or Partner receiving a distribution of a portion of its Capital Account) and as of the time of calculation, the amount by which the amount received (or to be received) upon such partial withdrawal or distribution as of such time plus an amount equal to any deemed distributions to such Partner for Federal income tax purposes pursuant to Section 752(b) of the Code resulting from its withdrawal or distribution is less than the product of (x) its "adjusted tax basis," for Federal income tax purposes, in its interest in the Partnership as of such time and (y) a fraction, the numerator of which is the amount received (or to be received) upon such partial withdrawal or distribution, and the denominator of which is the value of such Partner's Capital Account immediately prior to such partial withdrawal or distribution plus an amount equal to any deemed distributions that would be made to such Partner for Federal income tax purposes pursuant to Section 752(b) of the Code if such Partner had completely withdrawn its Capital Account(s) and (ii) the term "Negative Basis Partner" shall mean any Partner that withdraws some or all of its interest in the Partnership or receives a partial distribution in respect of a Capital Account and who has Full Negative Basis or Partial Negative Basis as of the effective date of its withdrawal (determined prior to any allocations made pursuant to this Section 3.09).
Sample 1
Partial Negative Basis means, with respect to any partially withdrawing Partner (or Partner receiving a distribution of a portion of its Capital Account) and as of the time of calculation, the amount by which the amount received (or to be received) upon such partial withdrawal or distribution as of such time plus an amount equal to any deemed distributions to such Partner for U.S. Federal income tax purposes pursuant to Section 752(b) of the Code resulting from its withdrawal or distribution is less than the product of (x) its “adjusted tax basis,” for U.S. Federal income tax purposes, in its interest in the Partnership as of such time and (y) a fraction, the numerator of which is the amount received (or to be received) upon such partial withdrawal or distribution, and the denominator of which is the value of such Partner’s Capital Account immediately prior to such partial withdrawal or distribution and (ii) the term “Negative Basis Partner” shall mean any Partner that withdraws some or all of its interest in the Partnership or receives a partial distribution in respect of a Capital Account and who has Full Negative Basis or Partial Negative Basis as of the effective date of its withdrawal (determined prior to any allocations made pursuant to this Section 3.09). Notwithstanding anything to the contrary in this Section 3.09, if a General Partner withdraws all or a portion of its Capital Account during any tax year or receives a partial distribution in respect of a Capital Account, the Managing General Partner may specially allocate income to such General Partner equal to the amount by which such withdrawal or distribution plus an amount equal to any deemed distributions to such General Partner exceed its adjusted tax basis, for income tax purposes, in its interest in the Partnership (determined prior to any such allocations).
Sample 1
Partial Negative Basis means, with respect to any Member whose Interests are partially repurchased by the Company and as of any time of calculation, the amount by which the amount received (or to be received) upon such partial repurchase as of such time plus an amount equal to any deemed distributions to such Member for U.S. Federal income tax purposes pursuant to Section 752 of the Code resulting from the repurchase of its Interests is less than the product of (x) its "adjusted tax basis," for U.S. Federal income tax purposes, in its interest in the Company as of such time and (y) a fraction, the numerator of which is the amount received (or to be received) plus an amount equal to any deemed distributions to such Member for U.S. Federal income tax purposes pursuant to Section 752 of the Code upon such partial repurchase, and the denominator of which is the value of such Member's Capital Account(s) whose Interests are partially repurchased by the Company immediately prior to such partial repurchase and (iii) the term "Negative Basis Member" shall mean any Member whose Interests are repurchased by the Company and who has Full Negative Basis or Partial Negative Basis as of the effective date of such repurchase (determined prior to any allocations made pursuant to this Section 5.7).
Sample 1

Related to Partial Negative Basis

  • Negative Basis means, with respect to any Member and as of any time of calculation, the amount by which the Member’s “adjusted tax basis,” for U.S. federal income tax purposes, in the Member’s Interest in the Company as of that time (determined without regard to any adjustments made to the “adjusted tax basis” by reason of any Transfer or assignment of the Interest, including by reason of death, and without regard to such Member’s share of the liabilities of the Company under Section 752 of the Code) exceeds the value of its Interest as of such time. As used in this Section 5.9, the term “Negative Basis Member” means any Member whose Interest is repurchased by the Company and who has Negative Basis as of the effective date of the repurchase, but such Member shall cease to be a Negative Basis Member at such time as it shall have received allocations pursuant to clause (i) of paragraph (c) equal to its Negative Basis as of the effective date of such repurchase.

  • Positive Basis means, with respect to any Partner and as of any time of calculation, the amount by which the total of the Partners’ Capital Accounts as of that time exceeds the Partner’s “adjusted tax basis,” for U.S. federal income tax purposes, in the Partner’s Units in the Partnership as of that time (determined without regard to any adjustments made to the “adjusted tax basis” by reason of any Transfer or assignment of Units, including by reason of death). As used in this Section 5.8, the term “Positive Basis Partner” means any Partner who or that withdraws from the Partnership and who or that has a Positive Basis as of the effective date of the Partner’s withdrawal. As used in this Section 5.8, the term “Negative Basis” means, with respect to any Partner and as of any time of calculation, the amount by which the Partner’s “adjusted tax basis,” for U.S. federal income tax purposes, in the Partner’s Units in the Partnership as of that time (determined without regard to any adjustments made to the “adjusted tax basis” by reason of any Transfer or assignment of Units, including by reason of death, and without regard to such Partner’s share of the liabilities of the Partnership under section 752 of the Code) exceeds the Partner’s Capital Account as of such time. As used in this Section 5.8, the term “Negative Basis Partner” means any Partner who or that withdraws from the Partnership and who or that has a Negative Basis as of the effective date of the Partner’s withdrawal.

  • Individual Case Basis or "ICB" shall have the meaning set forth in Exhibit I.

  • Base Rate Basis means a simple interest rate equal to the sum of (a) the Base Rate and (b) the Applicable Margin applicable to Base Rate Advances. The Base Rate Basis shall be adjusted automatically as of the opening of business on the effective date of each change in the Base Rate to account for such change, and shall also be adjusted to reflect changes of the Applicable Margin applicable to Base Rate Advances.

  • Interest Rate Basis means the Base Rate or the Eurodollar Basis, as applicable.

  • Substitute Basis has the meaning specified in Section 2.9(b).

  • Alternative Base Rate means the rate that has replaced LIBOR in customary market usage for determining floating interest rates in respect of bonds denominated in Dollars or, if the Independent Financial Adviser or the Issuer (in consultation with the Calculation Agent and acting in good faith and a commercially reasonable manner), as applicable, determines that there is no such rate, such other rate as the Independent Financial Adviser or the Issuer (in consultation with the Calculation Agent and acting in good faith and a commercially reasonable manner), as applicable, determines in its or the Issuer’s sole discretion is most comparable to LIBOR. If the Alternative Base Rate is determined, such Alternative Base Rate shall be the Alternative Base Rate for the remaining Interest Periods.

  • Alternate Base Rate means, for any day, a rate per annum equal to the greater of (a) the Prime Rate in effect on such day and (b) the Federal Funds Effective Rate in effect on such day plus 1/2 of 1%. Any change in the Alternate Base Rate due to a change in the Prime Rate or the Federal Funds Effective Rate shall be effective from and including the effective date of such change in the Prime Rate or the Federal Funds Effective Rate, respectively.

  • Fee Basis Amount As of any date of determination, the sum of (a) the Collateral Principal Amount, (b) the Aggregate Principal Balance of all Defaulted Obligations and (c) the aggregate amount of all Principal Financed Accrued Interest.

  • Eligible Basis has the meaning given to it in Section 42(d) of the Code.

  • Alternate Base Rate Loan means a Loan which bears interest at the Alternate Base Rate.

  • Corporate Base Rate means a rate per annum equal to the corporate base rate of interest announced by First Chicago from time to time, changing when and as said corporate base rate changes.

  • Market Disruption Rate means the rate (if any) specified as such in the Reference Rate Terms.

  • Alternate Base Rate Loans means Loans that bear interest at an interest rate based on the Alternate Base Rate.

  • Adjusted Daily Simple SOFR means an interest rate per annum equal to (a) Daily Simple SOFR, plus (b) 0.10%; provided that if Adjusted Daily Simple SOFR as so determined would be less than the Floor, such rate shall be deemed to be equal to the Floor for the purposes of this Agreement.

  • Excess Additional Book Basis has the meaning given such term in the definition of “Additional Book Basis Derivative Items.”

  • CMS Rate means the applicable swap rate for swap transactions in the Reference Currency with a maturity of the Designated Maturity, expressed as a percentage, which appears on the Relevant Screen Page as at the Specified Time on the relevant Interest Determination Date in question, all as determined by the Calculation Agent.

  • CMT Rate means, with respect to any Reset Date (in the following order of priority):

  • Alternate Base Rate Advance means an Advance which bears interest at the Alternate Base Rate.

  • Annual Percentage Rate or “APR” of a Receivable means the annual rate of finance charges stated in such Receivable.

  • Delinquency Rate With respect to any calendar month, the fraction, expressed as a percentage, the numerator of which is the aggregate outstanding principal balance of all Mortgage Loans 60 days Delinquent or more (including all foreclosures, bankruptcies and REO Properties) as of the close of business on the last day of such month, and the denominator of which is the Pool Balance as of the close of business on the last day of such month.

  • SOFR Rate means the rate that will be calculated by the Calculation Agent for each Accrual Period on the SOFR Adjustment Date as of the SOFR Determination Time (or, if the Benchmark is not SOFR, the Reference Time) and, except as provided below following a determination by the Administrator that a Benchmark Transition Event and its related Benchmark Replacement Date have occurred, shall mean, with respect to the Class A-2b Notes as of any SOFR Adjustment Date, a rate equal to Compounded SOFR; provided, that, the Administrator will have the right, in its sole discretion, to make applicable SOFR Adjustment Conforming Changes.

  • HICP Daily Inflation Reference Index means (A) in relation to the first calendar day of any given month, the HICP Monthly Reference Index of the third month preceding such month, and (B) in relation to a calendar day (D) (other than the first calendar day) in any given month (M), the linear interpolation of the HICP Monthly Reference Index pertaining respectively to the third month preceding such month (M - 3) and the second month preceding such month (M - 2) calculated in accordance with the following formula:

  • Interest Basis has the meaning given to it in the applicable Final Terms;