Pass-Through Income Tax Matter definition

Pass-Through Income Tax Matter means any matter relating to the determination of income, gain, loss, deduction or credits with respect to the operations of the business of the Company if the direct or indirect equity owners of the Company would be liable as a matter of law for Income Taxes attributable thereto (e.g., certain Income Tax liabilities for items of income, gain, loss, deduction and credit passed through to owners with respect to a partnership or disregarded entity for U.S. federal or applicable state, local or non-U.S. income tax purposes).
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Pass-Through Income Tax Matter means any matter relating to the determination of income, gain, loss, deduction or credits with respect to any Pass-Through Tax Return.
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Pass-Through Income Tax Matter means any matter relating to the determination of (A) any U.S. state non-resident withholding taxes with respect to the Group Companies or (B) any income taxes with respect to the operations of the business of the Company and/or any of its Subsidiaries if any of the Unitholders (or their direct and indirect owners) would be liable as a matter of Law for such income taxes (e.g., the income tax Liability for items of income, gain, loss, deduction and credit passed-through to owners with respect to a partnership for U.S. federal or applicable state and local income tax purposes).
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Examples of Pass-Through Income Tax Matter in a sentence

  • After the Closing Date, if Parent or any Target Group Member receives notice of any audit, demand, claim, proposed adjustment, assessment, examination or other administrative or court proceeding of any Target Group Member Entity relating to any Pass-Through Income Tax Matter with respect to any taxable period ending on or before the Closing Date (a “Tax Contest”), Parent shall notify the Unitholder Representative as soon as practicable and in any event within ten (10) days of receipt of such notice.

  • For the avoidance of doubt, notwithstanding anything to the contrary herein, to the extent permitted by Applicable Law, the parties shall cooperate to make a “push-out” election under Section 6226 of the Code or any analogous election under state or local Tax law with respect to any Pass-Through Income Tax Matter for any Pre-Closing Tax Period.


More Definitions of Pass-Through Income Tax Matter

Pass-Through Income Tax Matter means any matter relating to the determination of income, gain, loss, deduction or credits with respect to the operations of the business of the Company Entities if Truist Holdings, Truist Partners, the Buyer Entities or any other direct or indirect equity owner of the Company would be liable as a matter of law for income Taxes attributable thereto (e.g., the income Tax liability for items of income, gain, loss, deduction and credit passed through to owners with respect to a partnership or disregarded entity for US federal or applicable state, local or non-US income Tax purposes).
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Related to Pass-Through Income Tax Matter

  • Income Tax Return means any return, declaration, report, claim for refund, or information return or statement relating to Income Taxes, including any schedule or attachment thereto, and including any amendment thereof.

  • Non-Income Tax Return means any Tax Return relating to any Tax other than an Income Tax.

  • Federal Tax Certificate means the Issuer's Federal Tax Certificate dated as of the Issue Date, as the same may be amended or supplemented in accordance with the provisions thereof.

  • council tax benefit means council tax benefit under Part 7 of the SSCBA; “couple” has the meaning given by paragraph 4;

  • Income Tax Expense means for Borrower and its Subsidiaries, on a consolidated basis for any period, all state and federal income taxes (including without limitation Texas franchise taxes) paid or due to be paid during such period.

  • Pass-through entity means a partnership not treated as an association taxable as a C corporation for federal income tax purposes, a limited liability company not treated as an association taxable as a C corporation for federal income tax purposes, an S corporation, or any other class of entity from which the income or profits of the entity are given pass-through treatment for federal income tax purposes. "Pass-through entity" does not include a trust, estate, grantor of a grantor trust, or disregarded entity.

  • Income Tax means any federal, state, local, or foreign income tax, including any interest, penalty, or addition thereto, whether disputed or not.

  • Income Tax Returns means all Tax Returns relating to Income Taxes.

  • criminal tax matters means tax matters involving intentional conduct whether before or after the entry into force of this Agreement which is liable to prosecution under the criminal laws of the requesting Party;

  • Pre-Distribution Tax Period means any taxable period (or portion thereof) that ends on or before the Distribution Date.

  • Post-Distribution Tax Period means a Tax year beginning and ending after the Distribution Date.

  • Consolidated federal income tax return means a consolidated return filed for federal income tax purposes pursuant to section 1501 of the Internal Revenue Code.

  • Income Tax Act means the Income Tax Act, 1962 (Act No. 58 of 1962);

  • Production Tax Credit or “PTC” means the tax credit for electricity produced from certain renewable generation resources described in Section 45 of the Internal Revenue Code of 1986, as it may be amended or supplemented from time to time.

  • Pre-Tax Income means income, as determined by GAAP, prior to deduction of the Bonus Pool (as hereinafter defined) and income taxes, and if applicable, after the deduction of any bonus pool of a future officer bonus plan adopted by the Company relating to an applicable Award Year and adjustments approved by the Board as described herein.

  • Foreign Income Tax means any Tax imposed by any foreign country or any possession of the United States, or by any political subdivision of any foreign country or United States possession, which is an income tax as defined in Treasury Regulation Section 1.901-2, and any interest, penalties, additions to tax, or additional amounts in respect of the foregoing.

  • U.S. Tax Certificate has the meaning assigned to such term in Section 2.17(f)(ii)(D)(2).

  • Transaction Tax Deductions means any Tax deductions relating to (i) the Company Transaction Expenses, and (ii) repayment of the Indebtedness, including any unamortized deferred financing fees in connection with the Indebtedness.

  • Non-Income Tax means any Tax other than an Income Tax.

  • Tax Items shall have the meaning set forth in Section 6.4.A.

  • non-taxable territory means the territory which is outside the taxable territory;

  • PAYEE TAX REPRESENTATIONS Each representation specified in the Schedule as being made by it for the purpose of this Section 3(f) is accurate and true.

  • Distribution Taxes means any Taxes incurred as a result of the failure of the Intended Tax-Free Treatment of the Internal Restructuring, the Controlled Transfer or the Distribution.

  • Pass-Through Expenses means reasonable and actual out-of-pocket expenses incurred by Contractor for equipment, materials, supplies or other Services provided to LAUSD, but not including Contractor’s overhead costs, administrative expenses or other mark-ups.

  • Book-Tax Disparities means, with respect to any item of Contributed Property or Adjusted Property, as of the date of any determination, the difference between the Carrying Value of such Contributed Property or Adjusted Property and the adjusted basis thereof for federal income tax purposes as of such date. A Partner's share of the Partnership's Book-Tax Disparities in all of its Contributed Property and Adjusted Property will be reflected by the difference between such Partner's Capital Account balance as maintained pursuant to Exhibit B and the hypothetical balance of such Partner's Capital Account computed as if it had been maintained strictly in accordance with federal income tax accounting principles.

  • Prohibited Transaction Tax Any tax imposed under Section 860F of the Code. Prospectus: The prospectus dated February 21, 2006 as supplemented by the prospectus supplement dated February 23, 2006, relating to the Class A, Class B-1, Class B-2 and Class B-3 Certificates.