Received Interest definition
Examples of Received Interest in a sentence
In the present case, Transferor is transferring the Transferred Interest solely in exchange for the Received Interest.
Therefore, the transfer of the Received Interest would be taxable to the extent that the Received Interest is attributable to a USRPI.
In the present case, Transferor will transfer the Transferred Interest to the Transferee in exchange for the Received Interest.
Code section 897(g) provides that the transfer of a partnership interest is taxable to the extent that the partnership interest is attributable to USRPIs. Immediately after the exchange of the Transferred Interest for the Received Interest, the Transferee will indirectly hold the same potential USRPI that the Transferor currently holds indirectly.
The Facility Payment Amount payable by the Company on such Facility Fee Period End Date shall be paid to the Financing Provider by debiting such amount against the Received Interest Amount Balance (Begin) as of such Facility Fee Period End Date, up to the full amount of such Received Interest Amount Balance (Begin)).
Furthermore, the extent the Received Interest is attributable to a USRPI will be the same as the extent the Transferred Interest is attributable to a USRPI.
If the Facility Payment Amount payable by the Company on such Facility Fee Period End Date exceeds the Received Interest Amount Balance (Begin) on such date, the Company shall pay such excess of the Facility Payment Amount over the Received Interest Amount Balance (Begin) in cash to the Financing Provider on such Facility Fee Period End Date.
Therefore, under Code section 721(a), no gain or loss is recognized to Transferor or Transferee as a result of the contribution of the Transferred Interest in exchange for the Received Interest.
Immediately after the exchange of the Transferred Interest for the Received Interest, the Transferee will indirectly hold the same potential USRPI.
For purposes of clarity, the foregoing will not limit in any manner the obligation of the Financing Provider to make any payments or distributions to the Company pursuant to Section 4.01(a) (or, to the extent applicable, to apply the Aggregate Received Interest Amount to reduce the amounts payable by the Company to the Financing Provider pursuant to Section 4.01(a)).