Pre-Contribution Gain definition

Pre-Contribution Gain means, with respect to each Property owned by a Title Holding Partnership, that unrealized gain attributable to the excess of the fair market value of such Property on the date at which the Contributed Asset is contributed to the capital of the Partnership pursuant to Article IV hereof, over the adjusted tax basis of such Property on the date of such contribution; provided, however, that the amount of any Pre-contribution Gain associated with a Property shall be adjusted to account for allocations made in accordance with the provisions of paragraph (c) of this Section 7.3 and shall not, in any event, exceed that amount of gain actually allocated to the Partnership by a Title Holding Partnership as a result of the sale or other disposition of such Property.
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Pre-Contribution Gain means, with respect to each Project, any gain recognized under Section 704(c) of the Internal Revenue Code of 1986, as amended. This Section 2(d) shall inure to the benefit of only those Holders who recognize Pre-Contribution Gain in connection with the sale or other disposition of a Project.
Sample 1
Pre-Contribution Gain has the meaning given in Section 4.2(d) of Attachment 9.
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Examples of Pre-Contribution Gain in a sentence

  • The purpose of the restriction on building depth, like the restriction on gross floor area, is intended to ensure that there is appropriate light, air and amenity space on the lot.

  • As a 40% partner Harpo gets 40% of the cash and 40% of the taxable income.Under tax basis accounting Harpo has a big problem illustrated as follows: CASHTAXABLE INCOMETotals250,000620,000Groucho Pre-Contribution Gain (20,000Available to Partners250,000600,000Harpo PercentageX 40%X 40%Harpo Share$100,000$240,000 Harpo gets a cash distribution equal to his contribution as one would expect.

  • Harpo’s share of cash and taxable income is calculated as follows: CASHTAXABLE INCOMETotals250,000620,000Groucho Pre-Contribution Gain <20,000>Minimum Gain of Pre-Admission Partners <480,000>Available to all Partners250,000120,000Harpo Percentagex 40%x 40%Harpo Share$100,000$48,000 The Minimum Gain Charge-back to existing partners reduces, but does not eliminate the tax problems for Harpo.


More Definitions of Pre-Contribution Gain

Pre-Contribution Gain means that portion of the total taxable gain incurred by the Partnership with respect to an asset contributed by a Partner to the capital of the Partnership to the extent that such gain does not exceed the difference between (a) the initial Asset Value of the asset minus the amount of Depreciation claimed by the Partnership in respect of such asset and (b) the contributing Partner's adjusted basis in such asset for federal income tax purposes at the time the asset is contributed to the Partnership minus the actual depreciation, amortization or cost recovery deductions ("Tax Depreciation") claimed in respect of the asset for federal income tax purposes. If pursuant to Regulations promulgated under ss. 704(c) of the Code disproportionate allocations of Tax Depreciation deductions in respect of property contributed to the Partnership are not required to be made, or if no Tax Depreciation deductions are allowable with respect thereto, the amount of Pre-Contribution Gain shall instead be determined without reference to Depreciation deductions or Tax Depreciation deductions claimed in respect of the asset. In the event that the actual gain recognized upon the sale or other disposition of any such asset for federal income tax purposes is less than the amount determined above, Pre-Contribution Gain with respect to the asset shall be such lesser amount.
Sample 1

Related to Pre-Contribution Gain

  • Precontribution Gain has the meaning set forth in subparagraph 4(c) of Exhibit B.

  • Pre-Tax Contributions means, for any Participant, the aggregate of the Participant's Basic Pre-Tax Contributions and Supplemental Pre-Tax Contributions contributed to the applicable Pre-Tax Contribution Account.

  • After-Tax Contributions means amounts withheld from an Employee's Compensation pursuant to a Salary Reduction Agreement after all applicable state and federal taxes have been deducted. Such amounts are withheld for purposes of purchasing one or more of the Benefit Package Options available under the Plan.

  • Catch-Up Contributions means Salary Reduction Contributions made to the Plan that are in excess of an otherwise applicable Plan limit and that are made by Participants who are Age 50 or over by the end of their taxable years. An “otherwise applicable Plan limit” is a limit in the Plan that applies to Salary Reduction Contributions without regard to Catch-up Contributions, such as the limits on Annual Additions, the dollar limitation on Salary Reduction Contributions under Code Section 402(g) (not counting Catch-up Contributions) and the limit imposed by the Actual Deferral Percentage (ADP) test under Code Section 401(k)(3). Catch-up Contributions for a Participant for a taxable year may not exceed the dollar limit on Catch-up Contributions under Code Section 414(v)(2)(B)(i) for the taxable year. The dollar limit on Catch-up Contributions under Code Section 414(v)(2)(B)(i) is $1,000 for taxable years beginning in 2002, increasing by $1,000 for each year thereafter up to $5,000 for taxable years beginning in 2006 and later years. After 2006, the $5,000 limit will be adjusted by the Secretary of the Treasury for cost-of-living increases under Code Section 414(v)(2)(C). Any such adjustments will be in multiples of $500.

  • Excess Contributions means, with respect to any Plan Year, the excess of:

  • Excess Contribution means a contribution that exceeds the

  • Contribution Amounts the aggregate amount of capital contributions applied by the Borrower to permit the Incurrence of Contribution Indebtedness pursuant to Subsection 8.1(b)(xi).

  • Catch-Up Contribution means an Elective Deferral made to the Plan by a Catch-Up Eligible Participant that, during any taxable year of such Participant, exceeds one of the following:

  • State contribution means the lesser of:

  • Contribution Period means a period in respect of which contributions appropriate to the benefit in question are payable, have been paid or treated as paid under the legislation in question;

  • Net Termination Gain means, for any taxable year, the sum, if positive, of all items of income, gain, loss or deduction recognized by the Partnership after the Liquidation Date. The items included in the determination of Net Termination Gain shall be determined in accordance with Section 5.5(b) and shall not include any items of income, gain or loss specially allocated under Section 6.1(d).

  • Company Matching Contributions means any contributions made to the Company Matching Account of a Participant by a Participating Employer as provided for in Section 4.02.

  • Qualified Matching Contributions means Matching Contributions which are immediately nonforfeitable when made, and which would be nonforfeitable, regardless of the age or service of the Employee or whether the Employee is employed on a certain date, and which may not be distributed, except upon one of the events described under Section 401(k)(2)(B) of the Code and the regulations thereunder.

  • Matching Contributions means contributions made by the Employer on account of an "eligible Participant's" Elective Deferrals.

  • Contribution Amount has the meaning given in subsection 444-90(1A) in Schedule 1 of the Australian Taxation Administration Act 1953 (Cth).

  • Allocation Year Means (i) the period commencing on the Closing Date and ending on December 31, 2006, (ii) any subsequent period commencing on January 1 and ending on the following December 31, or (iii) any portion of the period described in clause (ii) for which the Company is required to allocate Profits, Losses and other items of Company income, gain, loss or deduction pursuant to Article V.

  • Company Contribution Amount means, for any one Plan Year, the amount determined in accordance with Section 3.5.

  • Employer Matching Contributions means the Employer matching contributions made to the Trust Fund pursuant to Article V (Employer Matching Contributions).

  • Contribution Account means an account, or accounts, into which the Accountholder and employer contributions are deposited by the TPA, and from which HSA dollars are swept into the Cash Account.

  • Company Contributions means the contributions made by the Company pursuant to Section 3.3.

  • Contribution Date has the meaning set forth in Section 4.3 hereof.

  • Taxable Allocation means, with respect to any Series, the allocation of any net capital gains or other income taxable for federal income tax purposes to a dividend paid in respect of such Series.

  • Employer Contributions means all amounts paid into ASRS by an

  • distribution losses means energy losses that result from the interaction of intrinsic characteristics of the distribution network such as electrical resistance with network voltages and current flows;

  • Qualified Matching Contribution means any employer contribution allocated to an Eligible Employee's account under any plan of an Employer or a Related Company solely on account of "elective contributions" made on his behalf or "employee contributions" made by him that is a qualified matching contribution as defined in regulations issued under Code Section 401(k), is nonforfeitable when made, and is distributable only as permitted in regulations issued under Code Section 401(k).

  • Contribution Share means, for any Guarantor in respect of any Excess Payment made by any other Guarantor, the ratio (expressed as a percentage) as of the date of such Excess Payment of (i) the amount by which the aggregate present fair salable value of all of its assets and properties exceeds the amount of all debts and liabilities of such Guarantor (including contingent, subordinated, unmatured, and unliquidated liabilities, but excluding the obligations of such Guarantor hereunder) to (ii) the amount by which the aggregate present fair salable value of all assets and other properties of the Borrower and all of the Guarantors other than the maker of such Excess Payment exceeds the amount of all of the debts and liabilities (including contingent, subordinated, unmatured, and unliquidated liabilities, but excluding the obligations of the Borrower and the Guarantors hereunder) of the Borrower and all of the Guarantors other than the maker of such Excess Payment; provided, however, that, for purposes of calculating the Contribution Shares of the Guarantors in respect of any Excess Payment, any Guarantor that became a Guarantor subsequent to the date of any such Excess Payment shall be deemed to have been a Guarantor on the date of such Excess Payment and the financial information for such Guarantor as of the date such Guarantor became a Guarantor shall be utilized for such Guarantor in connection with such Excess Payment. This Section 4.6 shall not be deemed to affect any right of subrogation, indemnity, reimbursement or contribution that any Guarantor may have under applicable law against the Borrower in respect of any payment of Guaranteed Obligations. Notwithstanding the foregoing, all rights of contribution against any Guarantor shall terminate from and after such time, if ever, that such Guarantor shall be relieved of its obligations pursuant to Section 8.4.