Passive Assets definition

Passive Assets. For purposes of this test, “passive assets” are those assets which generate (or are reasonably expected to generate) passive income (as defined above). Assets which generate partly passive and partly non-passive income are considered passive assets to the extent of the relative proportion of passive income (compared to non-passive income) generated in a particular taxable year by such assets. Please note the following: • A trade or service receivable is non-passive if it results from sales or services provided in the ordinary course of business. • Intangible assets that produce identifiable items of income, such as patents or licenses, are characterized in terms of the type of income produced. • Goodwill and going concern value must be identified to a specific income producing activity and are characterized in accordance with the nature of that activity. • Cash and other assets easily convertible into cash are passive assets, even when used as working capital. • Stock and securities (including tax-exempt securities) are passive assets, unless held by a dealer as inventory.
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Passive Assets. For purposes of this test, “passive assets” are those assets which generate (or are reasonably expected to generate) passive income (as defined above). Assets which generate partly passive and partly non-passive income are considered passive assets to the extent of the relative proportion of passive income (compared to non-passive income) generated in a particular taxable year by such assets. Please note the following: • A trade or service receivable is non-passive if it results from sales or services provided in the ordinary course of business. • Intangible assets that produce identifiable items of income, such as patents or licenses, are characterized in terms of the type of income produced. • Goodwill and going concern value must be identified to a specific income producing activity and are characterized in accordance with the nature of that activity. • Cash and other assets easily convertible into cash are passive assets, even when used as working capital. • Stock and securities (including tax-exempt securities) are passive assets, unless held by a dealer as inventory. Average value: For purposes of this test, “average fair market value” equals the average quarterly fair market value of the assets for the relevant taxable year. Look-through rule: if the Company owns, directly or indirectly, 25% of the stock by value of another corporation, the Company must take into account its proportionate share of the passive assets of such other corporation.
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Passive Assets. For purposes of this question, note that “passive assets” are those assets that generate (or are reasonably expected to generate) passive income (as defined in paragraph 2 above). Assets that generate partly passive and partly non-passive income are considered passive assets to the extent of the relative proportion of passive income (compared to non-passive income) generated in a particular taxable year by such assets. Please note the following:
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Examples of Passive Assets in a sentence

  • If the Vendor does not agree to bear such value-added tax, the economic benefit from, and the requirement to bear the costs towards, interests in the UK Passive Assets will be excluded from the UK Transaction and the Consideration for the UK Transaction will be adjusted by not more than 63%.

  • Monetized Passive Assets Strategy 1Develop and implement revenues, rates, and rate structure to meet Utility 2.0 objectives through 2025.

  • The Treatment of Cash and Non-Depreciable Assets as Passive Assets andthe Start-up Exception......................................................................................- 31 -B.

  • Figure 3 - Passive Assets Flowchart below provides an overview.Figure 3 - Passive Assets Flowchart ConstructionDry CommissioningOperationalThe following additional requirements are relevant to Water assets to complement the commissioning process.• Pr9032 – Procedure for Managing Water Quality During Mains Commissioning;• F10045 – Water Quality Mains Commissioning Form.

  • Attempts will be made to position sampling locations at least 65 feet apart to decrease potential overlapping use by mobile target invertebrates and small mammals.

  • Adjusted for the Transactions, the Group’s reported net debt to net total capital ratio as at 30 June 1 The Group’s site count includes sites for UK Unilateral Assets and certain UK Passive Assets in the United Kingdom, but excludes sites owned and operated by 3GIS in Sweden.

  • Table 5-1: Sewer Passive Assets Valuation Rules NOTE: The unit rates shown below are based on 2014 figures provided by the NSW Office of Water in the NSW Reference Rates Manual, with indexation for 2014/15 of 1.5%, and 2015/16 of 1.5%.

  • CFC Legislation, Passive Assets and the Impact of the ECJ’s Cadbury-Schweppes Decision.

  • Because of the complex and confusing holding company rules under the installment payment provision,13 a closely held business owner needs to consult a knowledgeable (i.e. expensive) tax advisor when using a holding company structure so as to preserve the benefits of the installment payment provision.• Congress Should Improve the Definition of Passive Assets under the Installment Payment Provision.

  • With effect on or about the date of Closing in respect of the UK Transaction, the Cellnex Counterparty will have the economic benefit from, and the requirement to bear the costs towards, interests in the UK Passive Assets.


More Definitions of Passive Assets

Passive Assets has the meaning ascribed to it in Section (3) of Exhibit D.
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Passive Assets. For purposes of this test, “passive assets” are those assets which generate (or are reasonably expected to generate) passive income (as defined above). Assets which generate partly passive and partly non-passive income are considered passive assets to the extent of the relative proportion of passive income (compared to non-passive income) generated in a particular taxable year by such assets. Please note the following: • A trade or service receivable is non-passive if it results from sales or services provided in the ordinary course of business. • Intangible assets that produce identifiable items of income, such as patents or licenses, are characterized in terms of the type of income produced.
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Passive Assets has the meaning set forth in Section 6.10(b)(x).
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Related to Passive Assets

  • Productive Assets means assets (including assets of a referent Person owned directly or indirectly through ownership of Capital Stock) of a kind used or useful in the Cable Related Business.

  • Excluded Personal Property has the meaning set forth in Section 2.2(c).

  • Subject Assets is defined in Section 2.2(c).

  • Operating Assets means all merchandise inventories, furniture, fixtures and equipment (including all transportation and warehousing equipment but excluding office equipment and data processing equipment) owned or leased pursuant to Capital Leases by the Company or a Restricted Subsidiary.

  • business vertical means a distinguishable component of an enterprise that is engaged in the supply of individual goods or services or a group of related goods or services which is subject to risks and returns that are different from those of the other business verticals.

  • Real Estate Business means homebuilding, housing construction, real estate development or construction and the sale of homes and related real estate activities, including the provision of mortgage financing or title insurance.

  • Included Assets has the meaning in Section 5.1(d)(ii)(A).

  • Company IT Assets means all Software, systems, serves, computers, hardware, firmware, middleware, networks, data communications lines, routers, hubs, switches and all other information technology equipment, and all associated documentation owned by or licensed, pursuant to a valid and enforceable license agreements, to the Company and its Subsidiaries.

  • Permitted Assets means any and all properties or assets that are used or useful in a Permitted Business (including Capital Stock in a Person that is a Restricted Subsidiary and Capital Stock in a Person whose primary business is a Permitted Business that shall become a Restricted Subsidiary immediately upon the acquisition of such Capital Stock by the Issuer or by a Restricted Subsidiary, but excluding any other securities).

  • Designated Assets means any property or assets (including Capital Stock of any Subsidiary) of Holdings, the Restricted Parent, the Issuer and their respective Restricted Subsidiaries constituting a business, a line or unit of a business or used in operating a business substantially as an entirety.

  • Qualified Assets means any of the following assets: (i) interests, rights, options, warrants or convertible or exchangeable securities of the Partnership; (ii) Debt issued by the Partnership or any Subsidiary thereof in connection with the incurrence of Funding Debt; (iii) equity interests in Qualified REIT Subsidiaries and limited liability companies (or other entities disregarded from their sole owner for U.S. federal income tax purposes, including wholly owned grantor trusts) whose assets consist solely of Qualified Assets; (iv) up to a one percent (1%) equity interest in any partnership or limited liability company at least ninety-nine percent (99%) of the equity of which is owned, directly or indirectly, by the Partnership; (v) cash held for payment of administrative expenses or pending distribution to security holders of the General Partner or any wholly owned Subsidiary thereof or pending contribution to the Partnership; and (vi) other tangible and intangible assets that, taken as a whole, are de minimis in relation to the net assets of the Partnership and its Subsidiaries.

  • Excluded Inventory shall have the meaning set forth in Section 2.1(c).

  • Transferred Assets means the assets, rights and properties of the Sellers that the Purchasers shall acquire as of the Closing.

  • Excluded Assets has the meaning set forth in Section 2.2.

  • Unimproved Real Property means Property in which the Company has an equity interest that was not acquired for the purpose of producing rental or other operating income, that has no development or construction in process and for which no development or construction is planned, in good faith, to commence within one (1) year.

  • Retained Assets has the meaning set forth in Section 2.2.

  • Non-Investment Personnel means any Employee that does not meet the definition of Investment Personnel as listed above.

  • Excluded Entities has the meaning set forth in Section 2.2(b)(iv).

  • Restricted Assets means all licenses, permits, franchises, approvals or other authorizations from any Governmental Authority from time to time granted to or otherwise held by the Company to the extent the same constitute “Excluded Assets” under (and as defined in) the Senior Lien Documents or the Junior Lien Documents or are similarly carved out from the granting clause or the collateral thereunder.

  • Field emission equipment means equipment which uses an x-ray tube in which electron emission from the cathode is due solely to the action of an electric field.

  • Business Assets means all tangible and intangible property and assets owned (either directly or indirectly), leased, licensed, loaned, operated or used, including all real property, fixed assets, facilities, equipment, inventories and accounts receivable, by the Corporation and the Subsidiaries in connection with the Business;

  • Women-owned small business concern means a small business concern-

  • Contributed Assets shall have the meaning as set forth in Section 2.2.

  • Excluded Real Property means (a) any fee-owned real property with a purchase price (in the case of real property acquired after the Effective Date) or Fair Market Value (in the case of real property owned as of the Effective Date, with Fair Market Value determined as of the Effective Date) of less than $3,500,000 individually, (b) any real property that is subject to a Lien permitted by Sections 6.02(iv), (xix), (xxii), (xxiii), (xxviii) or (xxxi), (c) any real property with respect to which, in the reasonable judgment of the Term Administrative Agent (confirmed by notice to the Borrower) the cost (including as a result of adverse tax consequences) of providing a Mortgage shall be excessive in view of the benefits to be obtained by the Lenders, (d) any real property to the extent providing a mortgage on such real property would (i) be prohibited or limited by any applicable law, rule or regulation (but only so long as such prohibition or limitation is in effect), (ii) violate a contractual obligation to the owners of such real property (other than any such owners that are the Borrower or Affiliates of the Borrower) that is binding on or relating to such real property (other than customary non-assignment provisions which are ineffective under the Uniform Commercial Code) but only to the extent such contractual obligation was not incurred in anticipation of this provision or (iii) give any other party (other than the Borrower or a wholly-owned Restricted Subsidiary of the Borrower) to any contract, agreement, instrument or indenture governing such real property the right to terminate its obligations thereunder (other than customary non-assignment provisions which are ineffective under the Uniform Commercial Code or other applicable law) and (e) any Leasehold.

  • Separate Business means each of the activities of the Licensee connected

  • Owned Real Properties has the meaning set forth in Section 3.16(b).