Tax Dispute Resolution Procedure definition

Tax Dispute Resolution Procedure means the procedures to be used by WMI, JPMC and the FDIC Receiver to reconcile issues associated with the calculation and estimation of Taxes, all as set forth in Section 2.4(i) hereof.
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Tax Dispute Resolution Procedure. Any disputed item shall be submitted to the national office of an independent accounting firm of national reputation selected by the Seller and reasonably acceptable to the Purchaser (the "Tax Dispute Accountants"). The Purchaser and the Seller shall present their arguments to the Tax Dispute Accountants within 15 days after such submission and the Tax Dispute Accountants shall resolve the dispute, in a fair and equitable manner and in accordance with the applicable Tax law, which determination shall be binding and conclusive on the parties, provided that any dispute arising with respect to a Tax Return submitted to the Seller for its review pursuant to Section 4.4.2(b) shall be resolved in favor of the Seller unless the Tax Dispute Resolution Accountants determine that there is no reasonable basis for the Seller's position. The Purchaser and the Seller shall each be responsible for one-half of the cost and fees of the Tax Dispute Accountants. Tax Reserve: $2,863,164, which is equal to the combined amount of the current liabilities for "State and Local Taxes Payable" with respect to the Company and its Subsidiaries, and Equitable Agri-Business, respectively, reflected on the December 31, 1996 Financial Statements, reduced by any payments made by the Companies to any state, local or foreign taxing authority during the period beginning on January 1, 1997 and ending on the Closing Date with respect to Taxes for which such liabilities were established. Tax Return: any report, return, statement or other written information required to be supplied to a taxing authority in connection with Taxes.
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Tax Dispute Resolution Procedure means the following procedure: any disputed item shall be submitted to an independent accounting firm of national reputation selected by Buyer and the Sellers' Representatives in accordance with the procedures set forth in Section 2.4(c) (the "TAX DISPUTE ACCOUNTANTS"). Buyer and the Sellers' Representatives shall present their arguments to the Tax Dispute Accountants within 30 days after such submission and the Tax Dispute Accountants shall resolve such dispute, in a fair and equitable manner and in accordance with applicable Tax law, which determination will be binding and conclusive on the parties. Buyer, on the one hand, and the Stockholders, on the other hand, shall each be responsible for one-half of the cost and fees of the Tax Dispute Accountants.
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Examples of Tax Dispute Resolution Procedure in a sentence

  • To the extent WMI, JPMC and the FDIC Receiver are unable to resolve any differences regarding a calculation or estimate undertaken pursuant to this Section 2.4, the Parties shall utilize the Tax Dispute Resolution Procedure.

  • In the event the parties are unable to agree on the amount of any such tax benefit or tax detriment, such dispute shall be resolved in accordance with the Tax Dispute Resolution Procedure.

  • If, as of the date that is 150 days after the Closing Date, there remains a dispute as to the form and content of the Section 338 Forms or the California Section 338(h)(10) Amount, then the dispute shall be resolved in accordance with the Tax Dispute Resolution Procedure, provided that the agreement pursuant to which the Tax Dispute Accountants are retained shall provide that such resolution shall be made no later than the date that is l80 days after the Closing Date.


More Definitions of Tax Dispute Resolution Procedure

Tax Dispute Resolution Procedure means the submission of any disputed tax item to the Signing Review Accountants, who shall make a binding determination with respect to such tax item. Such determination shall be accompanied by a written legal analysis upon which such determination shall be based, concluding that it is at least more likely than not that the treatment of the tax item as determined by the Signing Review Accountants is correct. If more than one potential determination with respect to the same tax item could satisfy the requirement of the preceding sentence, the determination of the Signing Review Accountants shall adopt the treatment supported by the highest level of substantive legal comfort. Notwithstanding the foregoing, if (in the judgment of the Signing Review Accountants) the treatment of any tax item would have a significant economic effect on only one Member (or one Member and its Affiliates), the affected Member's position shall prevail if the Signing Review Accountants determine that there is a reasonable basis for such position.
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Related to Tax Dispute Resolution Procedure

  • Dispute Resolution Procedure means the procedure for resolution of Disputes set forth in Article 26;

  • Dispute Resolution Process means the process described in clause 9

  • Dispute Resolution Procedures means the procedures outlined in Annexure A of the MSA Determination.

  • Dispute Resolution means the procedure set forth in this LGIP for resolution of a dispute between the Parties.

  • dispute resolution proceeding ’ means any process in which an alternative means of dispute resolution is used to resolve an issue in controversy in which a neutral is appointed and specified parties participate;

  • Alternative dispute resolution means mediation, arbitration, conciliation, or other nonjudicial procedure that involves a neutral party in the decisionmaking process. The form of alternative dispute resolution chosen pursuant to this article may be binding or nonbinding, with the voluntary consent of the parties.

  • Dispute Resolution Scheme means the Electricity and Gas Complaints Commission or such other dispute resolution scheme approved or provided for in accordance with section 95 of the Act;

  • Mediation means any process in which a mediator facilitates communication and negotiation between the parties to assist them in reaching a voluntary agreement regarding their dispute.

  • Expedited Dispute Timetable means the timetable set out in paragraph 164 of Call Off Schedule 11 (Dispute Resolution Procedure);

  • Arbitration means any arbitration whether or not administered by a permanent arbitral institution;

  • Tax Dispute has the meaning set forth in Section 5.06.

  • Complaints Procedure means the School's procedure for handling complaints from parents, as amended from time to time for legal or other substantive reasons, or in order to assist the proper administration of the School. It does not form part of the contract between you and the School. A copy of the most up-to-date procedure is on the School's website and is otherwise available from the School at any time upon request;

  • Arbitration Tribunal means an organ composed of an odd number of persons known as arbitrators, who decide on the solution of a conflict in which the parties have expressly waived recourse to the ordinary civil courts

  • Arbitrable Dispute means any dispute arising under or in connection with this Agreement.

  • Agreement Disputes shall have the meaning set forth in Section 6.1.

  • Arbitration Notice has the meaning set forth in Section 9.13.

  • Grievance Procedure is used in this Agreement, it shall be considered as including the arbitration procedure.

  • AAA Rules has the meaning set forth in Section 11.2.

  • Variation Procedure means the procedure for carrying out a Variation as set out in Clause 16.1 (Variation Procedure);

  • UNCITRAL Arbitration Rules means the arbitration rules of the United Nations Commission on International Trade Law.

  • Labor dispute as used here, means a strike, lockout, or other labor dispute between the Employer and its Employees, during which time the Employee is not paid by the Employer.

  • Dispute Board (DB) means the person or persons named as such in the SCC appointed by agreement between the Procuring Entity and the Contractor to make a decision with respect to any dispute or difference between the Procuring Entity and the Contractor referred to him or her by the Parties pursuant to GCC Sub-Clause 46.1 (Dispute Board) hereof.

  • Notice of Arbitration means the formal notice from the CONTRACTOR or the CUSTOMER to the other party referring a dispute to arbitration in accordance with the provisions of Schedule 2-9.

  • Formal Dispute means a written objection by an Interested Party to any of the following:

  • Billing Dispute means the dispute of an invoice prepared by an Operator to the Other Operator which is made in good faith.

  • Arbitration Panel shall have the meaning set forth in Section 3 hereof.