Examples of Tax Attributes in a sentence
The Debtors’ requested relief is intended to help ensure that any NOL assets and certain other Tax Attributes are protected, in the interim, while such review and confirmation remains pending.
Subject to Section 3.3, the Realized Tax Benefit (or the Realized Tax Detriment) for each Taxable Year is intended to measure the decrease (or increase) in the actual liability for Covered Taxes of the Corporate Taxpayer for such Taxable Year attributable to the Tax Attributes, determined using a “with and without” methodology.
A liability for the payable to parties subject to the TRA, and a reduction to stockholders’ equity, is accrued when (i) an exchange of a Paired Interest or non-corresponding Class A Units of Rani LLC has occurred and (ii) when it is deemed probable that the Tax Attributes associated with the exchange will be used to reduce the Company’s taxable income based on the contractual percentage of the benefit of Tax Attributes that the Company expects to receive over a period of time (Note 10).
To make an election under section 1017(b) (3)(E) or (4)(C), a taxpayer must enter the appro- priate information on Form 982, Reduc- tion of Tax Attributes Due to Discharge of Indebtedness (and Section 1082 Basis Ad- justment), and attach the form to a timely filed (including extensions) Fed- eral income tax return for the taxable year in which the taxpayer has COD in- come that is excluded from gross in- come under section 108(a).
REMIC Election and Special Tax Attributes We will elect to treat the Trust as a REMIC for federal income tax purposes.