Section 731(a definition

Section 731(a. Gain" means the gain of the Members, individually and cumulatively, as determined from time to time on December 31st of each year during the Repayment Event Period, in accordance with Section 731(a) and Treasury Regulation 1.731-1 and the Partnership Agreement, which arises from the lack of Qualified Liabilities of the Partnership and/or Qualified Liabilities of First Commercial on such December 31st allocable to the Members under Section 752 and Treasury Regulation 1.752.
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Examples of Section 731(a in a sentence

  • If the Contributor Representative believes that the distribution of such SRC Limited Partnership Units may be taxable to the converting holders under Section 731(a) of the Code it may request that the Operating Partnership offer to provide the converting Partners with the opportunity to enter into so- called "bottom-up" guarantees under terms and conditions set forth in Section 2(z) of the Tax Protection Agreement, mutatis mutandis.

  • If the Contributor Representative believes that the distribution of such SRC Limited Partnership Units may be taxable to the converting holders under Section 731(a) of the Code it may request that the Operating Partnership offer to provide the converting Partners with the opportunity to enter into so-called "bottom-up" guarantees under terms and conditions set forth in Section 2(z) of the Tax Protection Agreement, mutatis mutandis.

  • The distributive share of Company items of income, gain, loss, deduction, and ITCs as determined for federal income tax purposes allocated by the Company to the Holder of such Class A Unit and any gain recognized by such Holder under Section 731(a) of the Code, shall be calculated in accordance with a set of Tax Assumptions specified in the Fund Addendum applicable to all Projects within each particular Fund.

  • In the event that CytRx terminates this Agreement under Section 7.3.1(a) or Merck terminates this Agreement under Article 7.2, Merck's licenses pursuant to Section 2.1 shall terminate as of such termination date.

  • If the Contributor Representative believes that the distribution of such SRC Limited Partnership Units may be taxable to the converting holders under Section 731(a) of the Code it may request that the Operating Partnership offer to provide the converting Partners with the opportunity to enter into so- called “bottom-up” guarantees under terms and conditions set forth in Section 2(z) of the Tax Protection Agreement, mutatis mutandis.

  • Parent represents that it knows of no facts that would be inconsistent with (i) the VRLP Contribution qualifying as a tax-free transaction described under Sections 351(a) and 1032(a) of the Code, (ii) the VRLP Distribution with respect to Parent qualifying as a tax-free distribution under Section 731(a) of the Code, (iii) the Distribution qualifying for the Tax-Free Status, or (iv) the Separate Contribution qualifying as a partnership contribution described under Section 721(a) of the Code.

  • USC shall not have any right to purchase parking spaces in the Science Center Structure during the normal operating hours of the California Science Center and CAAM except for USC Football Games and the three additional Special or Major Events referenced in Section 7.3.1(a) above.

  • Each holder of Units agrees to take such actions and to enter into such agreements as the Company may reasonably request in order to carryout the intent and provisions of this Section 4.7. The Company and the holder agree to treat any such distribution as a distribution of securities of the Subsidiary under Code Section 731(a).

  • All distributions that, when made, would cause the recipient Member to recognize gain under Section 731(a) of the Code shall be considered advances against such Member’s allocable share of Profits for the Fiscal Year of the distribution.

  • It is intended that Highwoods’ distribution of property to the Distributees will be a non-taxable distribution of property pursuant to Section 731(a) of the Internal Code 1986 as amended.

Related to Section 731(a

  • Section 4(2) shall have the meaning set forth in the recitals of this Agreement.

  • Article 55 BRRD means Article 55 of Directive 2014/59/EU establishing a framework for the recovery and resolution of credit institutions and investment firms.

  • Section 510(b) Claim means any Claim arising from: (a) rescission of a purchase or sale of a security of the Debtors or an Affiliate of the Debtors; (b) purchase or sale of such a security; or (c) reimbursement or contribution allowed under section 502 of the Bankruptcy Code on account of such a Claim.

  • Section 385 Expanded Group shall have the meaning set forth in Treasury Regulation Section 1.385-1(c)(4) for an “expanded group”.

  • Section 510(b) Claims means any Claim or Interest against a Debtor subject to subordination under section 510(b) of the Bankruptcy Code, whether by operation of law or contract.