Partnership Tax Event means that the General Partner shall have requested and received an opinion of nationally recognized independent tax counsel experienced in such matters to the effect that there has been a Tax Action which affects any of the events described in (i) through (iii) below and that there is more than an insubstantial risk that (i) the Partnership is, or will be, subject to United States federal income tax with respect to income accrued or received on the Affiliate Investment Instruments or the Eligible Debt Securities, (ii) the Partnership is, or will be, subject to more than a DE MINIMIS amount of other taxes, duties or other governmental charges or (iii) interest payable by an Investment Affiliate with respect to the Debenture issued by such Investment Affiliate to the Partnership is not, or will not be, deductible by such Investment Affiliate for United States federal income tax purposes.
Partnership Tax Event means that the General Partner shall have requested and received an opinion of nationally recognized independent tax counsel experienced in such matters to the effect that there has been a Tax Action which affects any of the events described in (i) through (iii) below and that there is more than an insubstantial risk that (i) the Partnership is, or will be, subject to United States federal income tax with respect to income accrued or received on the Affiliate Investment Instruments or the Eligible Debt Securities, (ii) the Partnership is, or will be, subject to more than a de minimis amount of other taxes, duties or other governmental charges or (iii) interest payable by an Investment Affiliate with respect to the Initial Debentures is not, or will not be, deductible by such Investment Affiliate for United States federal income tax purposes.
Partnership Tax Event means that the General Partner shall have requested and received an opinion of nationally recognized independent tax counsel experienced in such matters to the effect that there has been a Tax Action that results in there being more than an insubstantial risk that (i) the Partnership is, or will be, subject to United States federal income tax with respect to income accrued or received on the Affiliate Investment Instruments or the Eligible Debt Securities, (ii) the Partnership is, or will be, subject to more than a de minimis amount of other taxes, duties or other governmental charges or (iii) interest payable by an Investment Affiliate with respect to any Initial Debenture issued by such Investment Affiliate to the Partnership is not, or will not be, deductible by such Investment Affiliate for United States federal income tax purposes.
Examples of Partnership Tax Event in a sentence
August 2016 $37,500 was transferred from the Scholarship Account/Wells Fargo to Sparta for Scholarships issued.
No Transfer of Units shall be made if such Transfer (i) would violate the then applicable federal and state securities laws or rules and regulations of the Commission, any state securities commission or any other governmental authorities with jurisdiction over such Transfer, (ii) would result in an Assignment Event or an Adverse Partnership Tax Event or (iii) would affect the Partnership's existence or qualification as a limited partnership under the Delaware Act.
If this matter were to be litigated and the Tax Court were to sustain the IRS's position on this matter, the judicial decision could constitute a Partnership Tax Event, which could result in an early redemption of the partnership preferred securities.
A Trust Tax Event, a Trust Investment Company Event, a Partnership Tax Event or a Partnership Investment Company Event, each as defined below, shall not have occurred and be continuing at the Closing Date.
More Definitions of Partnership Tax Event
Partnership Tax Event means that the Guarantor, as the general partner of the Partnership, shall have requested and received an opinion of nationally recognized independent tax counsel experienced in such matters to the effect that there has been a Tax Action which affects any of the events described in (i) through (iii) below and that there is more than an insubstantial risk that (i) the Partnership is, or will be subject to United States federal income tax with respect to income accrued or received on the Affiliate Investment Instruments or the Eligible Debt Securities (each as defined in the Limited Partnership Agreement), (ii) the Partnership is, or will be subject to more than a de minimis amount of other taxes, duties or other governmental charges or (iii) interest payable by one or more of the obligors with respect to the Affiliate Investment Instruments to the Partnership is not, or will not be, deductible by the Company for United States federal income tax purposes.
Partnership Tax Event means any one of the following: (i) Trust I or Partnership I becoming subject to more than a de minimis amount of taxes or similar assessments, (ii) RegCaPS I Payments are not effectively deductible in computing the taxable income of Fortis Insurance for Dutch corporate income tax purposes; (iii) Dividends received by Partnership I are included in the taxable income of Fortis Insurance for Dutch income tax purposes; or (iv) RegCaPS I Payments are subject to withholding tax in The Netherlands.
Partnership Tax Event means that Ultramar Diamond Shamrock Corporation in its capacity as general partner of the Partnership, shall have requested and received an opinion of independent tax counsel experienced in such matters to the effect that there has been a Tax Action which affects any of the events described in (i) through (iii) below and that there is more than an insubstantial risk that (i) the Partnership is, or will be subject to United States federal income tax with respect to income accrued or received on the Affiliate Investment Instruments or the Eligible Debt Securities (each as defined in the Limited Partnership Agreement), (ii) the Partnership is, or will be subject to more than a de minimis amount of other taxes, duties or other governmental charges or (iii) interest payable by one or more of the obligors with respect to the Affiliate Investment Instruments (as defined in the Amended and Restated Agreement of Limited Partnership of UDS Funding __, L.P.) to the Partnership is not, or will not be, deductible by the Company for United States federal income tax purposes.
Partnership Tax Event means that ML&Co. shall have requested and received an opinion of nationally recognized independent tax counsel experienced in these matters to the effect that there has been a Tax Action which affects any of the events described in (1) through (3) below and that there is more than an insubstantial risk that:
Partnership Tax Event has the meaning set forth in Annex C hereto.
Partnership Tax Event means any one of the following: (i) Trust II or Partnership II becoming subject to more than a de minimis amount of taxes or similar assessments; (ii) RegCaPS II Payments are not effectively deductible in computing the taxable income of Fortis Insurance for Dutch corporate income tax purposes; (iii) Dividends received by Partnership II are included in the taxable income of Fortis Insurance for Dutch income tax purposes; or (iv) RegCaPS II Payments are subject to withholding tax in The Netherlands.
Partnership Tax Event means that the General Partner: (A) shall have requested, received and delivered to the Partnership an opinion of nationally recognized independent tax counsel in the United States or the United Kingdom, as the case may be, experienced in such matters to the effect that there has been a Tax Action which relates to any of the events described in clauses (i) through (iii) below, and that, as a result of the occurrence of such Tax Action, there is more than an insubstantial risk that (i) the Partnership is, or will be, subject to United States federal income tax or United Kingdom corporation tax or income tax with respect to income accrued or received on the Affiliate Investment Instruments or the Eligible Debt Securities, (ii) the Partnership is, or will be, subject to more than a de minimis amount of other taxes, duties or other governmental charges, or (iii) interest payable by an Investment Affiliate with respect to the Affiliate Investment Instruments issued by such Investment Affiliate is not, or will not be, fully deductible by such Investment Affiliate for United States federal income tax or United Kingdom taxation purposes; or (B) has certified to the Partnership that, as a result of a Tax Action, Additional Amounts are, or will be, payable with respect to any payments made in respect of the Affiliate Investment Instruments, any Investment Guarantee, the Partnership Guarantee or the Preferred Trust Securities Guarantee, and has further certified to the Partnership that the General Partner cannot avoid the requirement to pay such Additional Amounts by using its reasonable efforts.