Partnership Adjustment definition

Partnership Adjustment shall have the meaning set forth in Section 6.18(b)(i).
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Partnership Adjustment shall have the meaning set forth in Section 9.1(d).
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Partnership Adjustment means any adjustment to a partnership-related item.
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Examples of Partnership Adjustment in a sentence

  • The Company (or its designee) shall be the “partnership representative” (the “Partnership Representative”) in connection with any audit of such Affected Tax Return and shall serve as Partnership Representative pursuant to the terms of this Agreement and the Partnership Adjustment Procedures that apply to audits conducted pursuant to the Budget Act including notifying the IRS of its designation as such, as may be necessary or appropriate under the Budget Act.

  • For all tax years prior to the tax year for which the Partnership Adjustment Procedures (as hereinafter defined) are first applicable to the Company, the Directors shall designate a Person as the “Tax Matters Member” of the Company in accordance with Section 6231(a)(7) of the Code (prior to amendment by the Budget Act (as hereinafter defined) and any regulations issued thereunder.

  • A Partnership subject to a Partnership Level Audit making an election pursuant to subsection C(3)(a)(iii) shall, within one hundred eighty (180) days of the Final Determination Date, file a State Partnership Adjustment Report with the [State Agency], pay the additional [State] tax owed by Composite Returns Partners and Nonresident Partners, and withhold and remit the tax owed by Withholding Partners.

  • A Partnership subject to a Partnership Level Audit that has made or been deemed to have made an election pursuant to subsection C(3)(a)(ii) shall, within one hundred eighty (180) days of the Final Determination Date, file a State Partnership Adjustment Report with the [State Agency], pay the additional [State] tax owed by Composite Returns Partners, and withhold and remit the tax owed by Withholding Partners.

  • In the event the Tiered Partner makes an election or is deemed to have made an election pursuant to subsection C(3)(a)(i), the Tiered Partner shall file a State Partnership Adjustment Report with [State Agency] and pay the additional [State] tax owed on behalf of its partners within ninety (90) days from the date the Amended State Schedule K-1 was mailed to the Tiered Partner.

  • A Partnership subject to a Partnership Level Audit that has made or been deemed to have made an election pursuant to subsection C(3)(a)(i) shall, within one hundred eighty(180) days of the Final Determination Date, file a State Partnership Adjustment Report with the [State Agency] and pay the additional [State] tax owed on behalf of its partners.

  • File a State Partnership Adjustment Report with [State Agency], pay the additional [State] tax owed by Composite Return Partners and Nonresident Partners, and withhold and remit the [State] tax owed by Withholding Partners, within ninety (90) days from the date the Amended State Schedule K-1 was mailed to the Tiered Partner.

  • File a State Partnership Adjustment Report with [State Agency], pay the additional [State] tax owed by Composite Return Partners, and withhold and remit the [State] tax owed by Withholding Partners, within ninety (90) days from the date the Amended State Schedule K-1 was mailed to the Tiered Partner.

  • Section 301.6225–1 is added to read as follows:§ 301.6225–1 Partnership Adjustment by the Internal Revenue Service.(a) Imputed underpayment paid by partnership in adjustment year—(1) In general.

  • Enter the balance on line 3.Line 4 - Fiduciary and Partnership Adjustment (Attach Schedule): If during the taxable year the estate or trust was a beneficiary of another estate or trust and is entitled to an adjustment from such other estate or trust, enter the amount of such adjustment on line 4.


More Definitions of Partnership Adjustment

Partnership Adjustment is determined with respect to the Company, the Partnership Representative shall promptly notify the Members of receipt of a notice of final partnership adjustment (“NFPA”). The Manager shall determine whether to file a petition in Tax Court, cause the Company to pay the amount of the Partnership Adjustment or make the election under Code Section 6226 and notify the Partnership Representative in writing within ten (10) days of their receipt of notice of the NFPA of their recommended action or actions.
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Partnership Adjustment means any adjustment in
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Partnership Adjustment. (as defined in Section 6241(2) of the Code) is finally determined with respect to the Company and the Tax Representative has not caused the Company to make the election under Section 6226 of the Code, then (i) the Members shall take such actions requested by the Tax Representative, including filing amended tax returns and paying any tax due in accordance with Section 6225(c)(2) of the Code; (ii) the Members shall cooperate with the Tax Representative’s efforts to reduce any imputed underpayment with respect to such Partnership Adjustment and shall promptly provide any information reasonably requested by the Tax Representative in connection with such efforts; and (iii) any imputed underpayment (or Partnership Adjustment that does not give rise to an imputed underpayment) shall be apportioned among the Members of the Company for the Fiscal Year in which such Partnership Adjustment is finalized in such manner as may be required (as determined by the Tax Representative) so that, to the maximum extent possible, the tax and economic consequences of the Partnership Adjustment and any associated interest and penalties are borne by the Members (including between former and current Members) based upon their interests in the Company for the “Reviewed Year” (as defined in Section 6225(d)(1) of the Code).
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Partnership Adjustment. Any adjustment to any “partnership- related item”, as such term is defined in Code Section 6241(2), or any Partner’s distributive share thereof, in any case as described in any applicable Regulations or other guidance prescribed by the IRS. Pass-through Partner: A pass-through entity that holds an interest in the Partnership, including a partnership (as described in Treas. Reg. § 301.7701-2(c)(1) including a foreign entity that is classified as a partnership under Treas. Reg. § 301.7701-3(b)(2)(i)(A) or (c), an S corporation, a trust (other than a trust described in the next sentence) and a decedent’s estate. For purposes of this definition, a pass-through entity does not include a disregarded entity described in Treas. Reg. § 301.7701-2(c)(2)(i) or a trust that is wholly owned by only one Person, whether the grantor or another Person, and the trust reports the owner’s information to payors under Treas. Reg. § 1.671-4(b)(2)(i)(A). Reviewed Year: The Partnership taxable year to which a Partnership Adjustment relates.
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Partnership Adjustment means any adjust- ment in the amount of any item of income, gain, loss, deduction, or credit of a partner- ship, or any partner’s distributive share thereof.
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Partnership Adjustment means any adjustment in the amount of any item of income, gain, loss, deduction, or credit of a partnership, or any partner’s distributive share thereof.
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Related to Partnership Adjustment

  • SOFR Adjustment means 0.10% (10 basis points) per annum.

  • True-Up Adjustment means any Annual True-Up Adjustment or Interim True-Up Adjustment, as the case may be.

  • Tax Adjustment has the meaning set forth in Section 4.7.

  • CPI Adjustment means the quotient of (i) the CPI for the month of January in the calendar year for which the CPI Adjustment is being determined, divided by (ii) the CPI for January of 2007.

  • Term SOFR Adjustment means a percentage equal to 0.10% per annum.

  • Partnership Minimum Gain has the meaning set forth in Regulations Section 1.704-2(b)(2), and the amount of Partnership Minimum Gain, as well as any net increase or decrease in Partnership Minimum Gain, for a Partnership Year shall be determined in accordance with the rules of Regulations Section 1.704-2(d).

  • OP Unit Economic Balance has the meaning set forth in Section 6.03(c) hereof.

  • Common Unit Economic Balance has the meaning set forth in Section 5.01(g) hereof.

  • Contract Term Adjustment means adjustment only as provided for in the three circumstances described in this Subsection. Under these circumstances, the contract term shall be adjusted in writing to include additional calendar days in one or more Normal Operating Seasons equal to the actual time lost, except as limited by paragraph (b) in this Subsection. To qualify for such adjustment, Purchaser shall give written notice of the lost time not later than 30 days after end of Normal Operating Season in which time was lost and at least 10 days before Termination Date. Contracting Officer shall make prompt written acknowledgment of such notice, indicating concurrence with the number of days in the notice or the number of days Forest Service considers as qualifying for the adjustment. Lost portions of days shall be disregarded in computing time lost. The three circumstances qualifying for a Contract Term Adjustment are:

  • Final Adjustment has the meaning set forth in Section 10.3.B(2) hereof.

  • Equity Adjustment means the dollar amount resulting by subtracting the Book Value, as of Bank Closing, of all Liabilities Assumed under this Agreement by the Assuming Bank from the purchase price, as determined in accordance with this Agreement, as of Bank Closing, of all Assets acquired under this Agreement by the Assuming Bank, which may be a positive or a negative number.

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

  • Post-Closing Adjustment has the meaning set forth in Section 2.04(b)(ii).

  • Partnership Percentage means the percentage share of each Partner in the Net Income or Net Loss of the Partnership. The Partners’ initial Partnership Percentages shall be proportionate to the Partners’ initial Capital Contributions to the Partnership. Thereafter, subject to Section 1.68(g), such Partnership Percentages shall be adjusted only to reflect a disproportionate Capital Contribution by one or more Partners or a disproportionate distribution to one or more Partners, with disproportion being determined in accordance with Sections 4.2(a) and 4.5(b), except as set forth in Section 1.68(f).

  • Capitalization Adjustment means any change that is made in, or other events that occur with respect to, the Common Stock subject to the Plan or subject to any Purchase Right after the date the Plan is adopted by the Board without the receipt of consideration by the Company through merger, consolidation, reorganization, recapitalization, reincorporation, stock dividend, dividend in property other than cash, large nonrecurring cash dividend, stock split, liquidating dividend, combination of shares, exchange of shares, change in corporate structure or other similar equity restructuring transaction, as that term is used in Financial Accounting Standards Board Accounting Standards Codification Topic 718 (or any successor thereto). Notwithstanding the foregoing, the conversion of any convertible securities of the Company will not be treated as a Capitalization Adjustment.

  • Final Adjustment Amount has the meaning set forth in Section 2.4(c).

  • 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.

  • Capital Account Limitation has the meaning set forth in Section 4.05(b) hereof.

  • Partnership Unit Designation shall have the meaning set forth in Section 4.2.A hereof.

  • General Partner Unit means a fractional part of the General Partner Interest having the rights and obligations specified with respect to the General Partner Interest. A General Partner Unit is not a Unit.

  • Adjustment Fraction shall have the meaning set forth in Section 11(a)(i) hereof.

  • Net Adjustment Amount means an amount, which may be positive or negative, equal to the Closing Net Working Capital as finally determined pursuant to this Section 2.9 minus the Preliminary Net Working Capital as set forth on the Preliminary Closing Statement;

  • 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 Unit means, with respect to any class of Partnership Interest, a fractional, undivided share of such class of Partnership Interest issued pursuant to Sections 4.1 and 4.3 (including Performance Units). The ownership of Partnership Units may be evidenced by a certificate for units substantially in the form of Exhibit D-1 or D-2 hereto or as the General Partner may determine with respect to any class of Partnership Units issued from time to time under Sections 4.1 and 4.3.

  • Partnership Loan has the meaning provided in Section 5.2(c) hereof.

  • Market Value Adjustment means, on a given date, an amount equal to the lesser of (x) 98% and (y) a percentage determined according to the following formula: Market Value Adjustment = 98% – [(10yrCMTt – 10yrCMTlaunch) ×Duration], where 10yrCMTt = the 10-Year Treasury Constant Maturity Rate published each business day by the Board of Governors of the Federal Reserve System, or, if such rate ceases to be published, a successor rate reasonably determined by the Trustees (the “10-Year CMT”), on such repurchase date; 10yrCMTlaunch = the 10-Year CMT as of the end of the Initial Offering Period; and Duration = an estimate of the duration of the periodic interest payments of a hypothetical coupon-paying U.S. Government Security with a 25-year maturity, calculated by the Trust’s Investment Manager as of the end of the Initial Offering Period;