Tax Equity Arrangement definition

Tax Equity Arrangement means an investment structure or arrangement involving one or more investors seeking a target internal rate of return that includes federal income tax credits and/or tax depreciation (each, a “Tax Equity Investor”) and generally (i) described in Revenue Procedures 2001-28 (sale leaseback (with or without “leverage”)), 2007-65 (flip partnership) or 2014-12 (flip partnership and master tenant partnership) as those revenue procedures are reasonably applied or analogized to a solar project transaction (as opposed to a wind farm or rehabilitated real estate project) or (ii) contemplated by Section 50(d)(5) of the Code (a pass- through/inverted lease).
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Tax Equity Arrangement means an investment structure or arrangement involving one or more investors seeking a target internal rate of return that includes federal income tax credits and/or tax depreciation (each, a “Tax Equity Investor”) and generally (i) described in Revenue Procedures 2001-28 (sale leaseback (with or without “leverage”)), 2007-65 (flip partnership) or 2014-12 (flip partnership and master tenant partnership) as those revenue procedures are
Sample 1
Tax Equity Arrangement means an investment structure or arrangement involving one or more investors seeking a target internal rate of return that includes federal income tax credits and/or tax depreciation (each, a “Tax Equity Investor”) and generally (i) described in Revenue 36 NTD: Insert “ninety” and “90” as appropriate (unless there is an uneven distribution of Delay Liquidated Damages after the Guaranteed Substantial Completion Date). Procedures 2001-28 (sale leaseback (with or without “leverage”)), 2007-65 (flip partnership) or 2014-12 (flip partnership and master tenant partnership) as those revenue procedures are reasonably applied or analogized to a solar project transaction (as opposed to a wind farm or rehabilitated real estate project) or (ii) contemplated by Section 50(d)(5) of the Code (a pass- through/inverted lease).
Sample 1

Examples of Tax Equity Arrangement in a sentence

  • In the event that Buyer secures a Tax Equity Arrangement for the Transactions, FERC and other regulatory approvals may be included as Buyer’s Regulatory Approvals and additional language added to the Agreement to address such approvals.

Related to Tax Equity Arrangement

  • Access Arrangement means an arrangement for access to a Covered Pipeline that has been approved by the Relevant Regulator.

  • Tax Sharing Arrangement means any written or unwritten agreement or arrangement for the allocation or payment of Tax liabilities or payment for Tax benefits with respect to a consolidated, combined or unitary Tax Return which includes the Company.

  • Compensation Arrangement means any direct or indirect compensatory payment or other financial agreement, arrangement or understanding with any person or entity other than the Corporation, including any agreement, arrangement or understanding with respect to any direct or indirect compensation, reimbursement or indemnification in connection with candidacy, nomination, service or action as a nominee or as a director of the Corporation;

  • legal arrangement means a trust or other similar arrangement;

  • Foreign Benefit Arrangement any employee benefit arrangement mandated by non-US law that is maintained or contributed to by any Group Member or any ERISA Affiliate.

  • Benefit Arrangement means at any time an employee benefit plan within the meaning of Section 3(3) of ERISA which is not a Plan or a Multiemployer Plan and which is maintained or otherwise contributed to by any member of the ERISA Group.

  • referral arrangement means any arrangement in which a registrant agrees to pay or receive a referral fee;

  • Multiple employer welfare arrangement means a multiple employer welfare arrangement

  • Share Compensation Arrangement means any stock option, stock option plan, employee stock purchase plan or any other compensation or incentive mechanism involving the issuance or potential issuance of Shares, including a share purchase from treasury which is financially assisted by the Corporation by way of a loan, guarantee or otherwise;

  • Non-Exempt Severance Arrangement means a severance arrangement or other agreement between the Participant and the Company that provides for acceleration of vesting of an Award and issuance of the shares in respect of such Award upon the Participant’s termination of employment or separation from service (as such term is defined in Section 409A(a)(2)(A)(i) of the Code (and without regard to any alternative definition thereunder) (“Separation from Service”) and such severance benefit does not satisfy the requirements for an exemption from application of Section 409A provided under Treasury Regulations Section 1.409A-1(b)(4), 1.409A-1(b)(9) or otherwise.

  • Change in Control Agreement means a written Change in Control Agreement between an employee and the Company or an Affiliate.

  • Travel Arrangements means: (a) transportation: (b) accommodations: and (c) other specified services arranged by the Travel Supplier for the covered trip.

  • Payroll Tax Executive Order means the Presidential Memorandum on Deferring Payroll Tax Obligations in Light of the Ongoing COVID-19 Disaster, as issued on August 8, 2020 and including any administrative or other guidance published with respect thereto by any Taxing Authority (including IRS Notice 2020-65).

  • Employee Benefits Agreement means each and collectively all employment, retirement, severance, indemnification, and similar or related agreements, arrangements, plans and policies with the members of the Debtors’ management team or directors as of the Petition Date, other than such benefits for former employees of MBTL and Retirees.

  • Life-of-the-unit, firm power contractual arrangement means a unit participation power sales agreement under which a utility or industrial customer reserves, or is entitled to receive, a specified amount or percentage of nameplate capacity and associated energy from any specified unit and pays its proportional amount of such unit's total costs, pursuant to a contract:

  • Severance Plan means any severance plan maintained by the Company that is applicable to the Participant.

  • Employee Matters Agreement shall have the meaning set forth in the Separation Agreement.

  • Health benefits plan means a benefits plan which pays or

  • Tax Protection Agreement means that certain Tax Protection Agreement dated as of the date hereof, by and among the REIT, the OP and the parties identified as a signatory on Schedule A thereto.

  • Transaction Payroll Taxes means the employer portion of any employment or payroll Taxes with respect to any bonuses, severance, option cashouts, Change in Control Payments or other compensatory payments in connection with the transactions contemplated by this Agreement, whether payable by Buyer, the Company or its Subsidiaries.

  • Section 409A Change in Control means a change in the ownership or effective control of the Company, or in the ownership of a substantial portion of the Company’s assets, as provided in Section 409A(a)(2)(A)(v) of the Code and Treasury Regulations Section 1.409A-3(i)(5) (without regard to any alternative definition thereunder).

  • Continuing care retirement community means a residential

  • Arrangement Agreement has the meaning ascribed thereto in the recitals hereof;

  • Pension Benefits Act means The Pension Benefits Act of Ontario and regulations thereunder as amended from time to time.

  • Project labor agreement means an agreement by which labor organizations agree to terms and conditions of employment, to cooperate in resolving labor disputes, and to maintain labor peace on the Project.

  • Company Equity Plan means the (a) Company’s Amended and Restated 2017 Equity Incentive Plan and (b) each other plan that provides for the award to any current or former director, manager, officer, employee, individual independent contractor or other service provider of any Group Company of rights of any kind to receive Equity Securities of any Group Company or benefits measured in whole or in part by reference to Equity Securities of any Group Company.