Reviewed Year Partner definition

Reviewed Year Partner is defined in Section 6.11(c) hereof.
Sample 1
Reviewed Year Partner. Any Person who held an interest in the Partnership at any time during the Reviewed Year. Revised Partnership Audit Rules: Subchapter 63C of the Code (as amended by the Bipartisan Budget Act of 2015, P.L. 114-74 and the Protecting Americans from Tax Hikes Act of 2015, P.L. 114-113), and the Treasury Regulations promulgated thereunder, as amended from time to time. Taxes: Any tax, penalties, additions to tax, additional amounts, and interest as described in Section 6226 of the Code.
Sample 1
Reviewed Year Partner. Any Person who held an interest in the Partnership at any time during the Reviewed Year.
Sample 1

Examples of Reviewed Year Partner in a sentence

  • The Proposal shifts the collection of federal income tax due, as a result of an audit examination, not only to the partnership but also to each Reviewed Year Partner and each Adjustment Year Partner (regardless of whether they were owners during the “review year”).

  • Except as hereinafter provided, if a Push-Out Election is made, each Reviewed Year Partner shall take into account its allocable share of the Partnership Adjustments that relate to the specified Imputed Underpayment and shall be liable for any Taxes as described in Section 6226 of the Code and any applicable Treasury Regulations or other guidance prescribed by the IRS.

  • Additionally, assessing tax at the partnership level, combined with joint and several liability for any Reviewed Year Partner or any Adjustment Year Partner, would put partners in partnerships in a worse position (from a U.S. income tax liability viewpoint) than shareholders in a corporation.

  • Notwithstanding the foregoing, to the extent permitted by law, any Reviewed Year Partner that is a partnership or S corporation may, at its option and in accordance with any applicable Treasury Regulations or other guidance prescribed by the IRS, elect (in lieu of paying its allocable share of such Partnership Adjustments) to push out the liability for Taxes attributable to such Partnership Adjustments to its Partners (including Indirect Partners).

  • Also, since the IRS is not a party to any agreement between the partners, the IRS can still pursue action against each Reviewed Year Partner and each Adjustment Year Partner.

  • If a Push-Out Election is made, the Partnership Representative shall furnish to each Reviewed Year Partner and the IRS, for each Reviewed Year within sixty (60) days after the date all of the Partnership Adjustments to which the statement relates are finally determined, a statement that includes all items and information required under any applicable Regulations, forms, instructions, and other guidance prescribed by the IRS.

  • The government may then go through a process of soliciting bids fromvendors.

  • If a Push- Out Election is made, the Partnership Representative shall furnish to each Reviewed Year Partner and the IRS, for each Reviewed Year within sixty (60) days after the date all of the Partnership Adjustments to which the statement relates are finally determined, a statement that includes all items and information required under any applicable Regulations, forms, instructions, and other guidance prescribed by the IRS.

Related to Reviewed Year Partner

  • Reviewed Year has the meaning ascribed to said phrase under Section 6225(d)(1) of the Code.

  • Deferred member means a person who elected to receive deferred vested retirement

  • Lead Partner means the lead partner of a joint venture, as described in Sub-Clause

  • Team Member means an individual who is allowed to access the Cloud Service but is only granted membership in groups associated with “Team Member” permissions for the Cloud Service.2

  • Employee Member means a member of the “Bargaining Unit”.

  • Election cycle means the period beginning on the first day persons are eligible to

  • Covered Executive means any “executive officer” of the Company as defined under Rule 10D-1.

  • LTIP Unitholder means a Partner that holds LTIP Units.

  • Named Executive means any individual who, on the last day of the Company’s fiscal year, is the chief executive officer of the Company (or is acting in such capacity) or among the four most highly compensated officers of the Company (other than the chief executive officer). Such officer status shall be determined pursuant to the executive compensation disclosure rules under the Exchange Act.

  • Ongoing employee means an employee who has been employed for at least one complete standard measurement period.

  • Class Year Study means a Class Year Interconnection Facilities Study as that term is defined in OATT Section 25 (OATT Attachment S).

  • Faculty Member means any person hired by the college or District to conduct classroom or teaching activities or who is otherwise considered by the college to be a member of faculty.

  • Spouse or partner means a person (including same sex partners) who lives with the principal policy holder in a marital or de facto relationship.

  • Post-Distribution Period means any Taxable period (or portion thereof) beginning after the Distribution Date.

  • Team Members means the members of the Team, jointly and severally;

  • Eligible Executive means an employee of the Company selected as being eligible to participate in this Plan under Section C.1.a.

  • First Year means the intake group of Students for the most junior class or year in a school.

  • 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;

  • Profit Distribution Date means the date on which the Management Company decides to distribute the profits (if any).

  • Benefit Distribution Date means the date upon which all or an objectively determinable portion of a Participant’s vested benefits will become eligible for distribution. Except as otherwise provided in the Plan, a Participant’s Benefit Distribution Date shall be determined based on the earliest to occur of an event or scheduled date set forth in Articles 4 through 9, as applicable.

  • Election Year means a year in which ordinary elections for local governments are required to be held;

  • Taxable Year means a taxable year of the Corporate Taxpayer as defined in Section 441(b) of the Code or comparable section of state or local tax law, as applicable (and, therefore, for the avoidance of doubt, may include a period of less than 12 months for which a Tax Return is made), ending on or after the IPO Date.

  • Committee Member means a member of the Committee.

  • Annual Membership Fee shall have the meaning specified in the Credit Card Agreement applicable to each Account for annual membership fees or similar terms.

  • Deferral Year means each calendar year during which the Trustee makes, or is entitled to make, Compensation Deferrals under Section 3 hereof.

  • Partner Group means any legal entity that has direct or indirect Control over the Partner and only as long as that legal entity maintains direct or indirect Control (“Parent Companies”) as well as all Associated Companies of the Parent Companies.