Related member definition
Related member means a person that, with respect to the taxpayer during all or any portion of the taxable year, is either a related entity, a component member as defined in section 1563(b) of the Internal Revenue Code, or a person to or from whom there is attribution of stock ownership in accordance with section 1563(e) of the Internal Revenue Code except, for purposes of determining whether a person is a related member under this division, "twenty per cent" shall be substituted for "5 percent" wherever "5 percent" appears in section 1563(e) of the Internal Revenue Code.
Related member means a person that, with respect to the
Related member means a person that, with respect to the Taxpayer during any portion of the Taxable Year, is any one of the following:
1. An individual stockholder, if the stockholder and the members of the stockholder’s family (as defined in Section 318 of the Internal Revenue Code, 26 U.S.C. § 318) own directly, indirectly, beneficially, or constructively, in the aggregate, at least 50% of the value of the Taxpayer’s outstanding stock;
2. A partnership, estate, or trust of any partner or beneficiary, if the partnership, estate, or trust, and its partners or beneficiaries own directly, indirectly, beneficially, or constructively, in the aggregate, at least 50% of the profits, equity, capital, stock, or value of the Taxpayer;
3. A corporation, and any party related to the corporation in a manner that would require an attribution of stock from the corporation to the party or from the party to the corporation under the attribution rules of Section 318 of the Internal Revenue Code, 26 U.S.C. § 318, if the Taxpayer owns directly, indirectly, beneficially, or constructively at least 50% of the value of the corporation’s outstanding stock;
4. A corporation and any party related to that corporation in a manner that would require an attribution of stock from the corporation to the party or from the party to the corporation under the attribution rules of Section 318 of the Internal Revenue Code, 26 U.S.C. § 318, if the corporation and all such related parties own in the aggregate at least 50% of the profits, equity, capital, stock, or value of the Taxpayer; or
5. A person to or from whom there is attribution of stock ownership in accordance with Section 1563(e) of the Internal Revenue Code (26 U.S.C. § 1563), except, for purposes of determining whether a person is a Related Member under this paragraph, twenty percent (20%) shall be substituted for five percent (5%) wherever five percent (5%) appears in Section 1563(e) of the Internal Revenue Code.
Examples of Related member in a sentence
The thirty (30) days shall run from the date on which the Company, the Related Member Parties, or the Guarantor, as applicable, receives a written notice of the Default from the EIC.
The Company, the Related Member Parties, and the Guarantor shall provide the authorized parties with access during regular business hours to persons and records for the purpose of monitoring, evaluating, or auditing this Agreement and their performance hereunder.
The Company, the Related Member Parties, the Guarantor and their employees, officers and executives are not employees or agents of the State or any agency thereof; nor are the State, its employees, officers and executives, agents or employees of the Company, the Related Member Parties, or the Guarantor.
The Company, the Related Member Parties, and the Guarantor shall use their reasonable best efforts to comply with any reasonable request for such access to persons or records by an authorized party, within ten (10) business days of the making thereof.
An Authorized Representative of the Guarantor shall certify the Company’s and Related Member Parties’ annual certifications, and, with respect to itself, shall make the certifications required in Paragraph 3.7(b)(iv), (v) and (vii), and shall provide any information required by Paragraph 3.7(b)(viii) and (ix).
More Definitions of Related member
Related member means a person that, with respect to the taxpayer during all or any portion of the
Related member means a person or entity that, with
Related member means a partnership or corporation which:
Related member means a person that, with respect to the taxpayer during all or any portion of the taxable year, is a related entity, a component member as defined in Section 1563(b) of the Internal Revenue Code, or is a person to or from whom there is attribution of stock ownership in accordance with Section 1563(e) of the Internal Revenue Code.
Related member means a person that, with respect to the Company during any portion of the taxable year, is any one of the following:
1. An individual stockholder, if the stockholder and the members of the stockholder's family (as defined in Section 318 of the Internal Revenue Code) own directly, indirectly, beneficially, or constructively, in the aggregate, at least 50% of the value of the Company’s outstanding stock.
2. A partnership, estate, trust and any partner or beneficiary, if the partnership, estate, or trust, and its partners or beneficiaries own directly, indirectly, beneficially, or constructively, in the aggregate, at least 50% of the profits, capital, stock, or value of the Company.
3. A corporation, and any party related to the corporation in a manner that would require an attribution of stock from the corporation under the attribution rules of Section 318 of the Internal Revenue Code, if the Company owns directly, indirectly, beneficially, or constructively at least 50% of the value of the corporation's outstanding stock.
4. A corporation and any party related to that corporation in a manner that would require an attribution of stock from the corporation to the party or from the party to the corporation under the attribution rules of Section 318 of the Internal Revenue Code, if the corporation and all such related parties own in the aggregate at least 50% of the profits, capital, stock, or value of the Company.
5. A person to or from whom there is an attribution of stock ownership in accordance with Section 1563(e) of the Internal Revenue Code, except, for purposes of determining whether a person is a related member under this paragraph, 20% shall be substituted for 5% wherever 5% appears in Section 1563(e) of the Internal Revenue Code.
Related member means a person that, with respect to the entity during all or any portion of the taxable year, is:
Related member means a person that, with respect to the taxpayer during all or any portion of the taxable year, is either a related entity, a component member as defined in