Tax-exempt Investor definition

Tax-exempt Investor means: (a) pension plans (as that term is defined in Section 3(2)(A) of ERISA), including qualified pension, profit-sharing and other employer retirement benefits plans (including Xxxxx [H.R. 10] Plans) and trusts, bank commingled trust funds for such plans and Individual Retirement Accounts, and (b) permitted transferees and permitted assigns of Units from a Person described in (a) above.
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Tax-exempt Investor means (i) a Limited Partner that is a U.S. person for U.S. federal income tax purposes and that is generally exempt from
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Tax-exempt Investor shall have the meaning set forth in Section 3.09(b).
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Examples of Tax-exempt Investor in a sentence

  • Accordingly, no income allocable by the Fund to a Tax Exempt Investor will be included in the income of such Tax Exempt Investor in calculating its UBTI.(9) ------------- (9) In Priv.

  • However, those types of income can be characterized as UBTI if they are derived from "debt-financed property."(5) For example, if a Tax Exempt Investor borrows money to purchase shares of the Fund, the income received by the Tax Exempt Investor from the Fund would be debt-financed income and, thus, UBTI as a result of the Tax Exempt --------------- (3) Codess.512(b)(1).

  • A Tax Exempt Investor might also receive or be deemed to receive UBTI as a result of a pass-through of UBTI from an entity in which it invests.

  • A Tax Exempt Investor will not Receive UBTI as a Result of Investment in the Fund or the Fund's Investment in the Company.

  • As described above, a Tax Exempt Investor in an organization treated as a partnership for federal income tax purposes will be attributed its allocable share of UBTI generated by the partnership's activities.

  • This opinion does not address the potential for a Tax Exempt Investor to generate UBTI from its own activities; rather it addresses only the potential that a Tax Exempt Investor might receive UBTI as a result of the activities of the Fund, the Company or the Portfolio.

  • The Company shall use its best efforts to conduct its affairs in a manner that does not cause any Tax Exempt Investor (as defined below) to have any items of gross income that constitute “unrelated business taxable income” as that term is defined in section 512 of the Code (“UBTI”).


More Definitions of Tax-exempt Investor

Tax-exempt Investor means and include (1) any Member exempt from federal income taxation pursuant to section 501 of the Code, and (2) any Member that both (x) is taxable as a partnership or other entity treated as transparent or a pass through for United States federal income tax purposes and (y) has as a partner (or other equity owner) any Entity exempt from federal income taxation pursuant to section 501 of the Code. Subject to the terms and conditions of this Agreement, the obligations of the Company in this regard shall include, but shall not be limited to, the following:
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Related to Tax-exempt Investor

  • Tax Exempt Person means a person who is exempt from tax under Part I of the Tax Act.

  • Exempt Investor means any of the following Irish Residents: (i) the Administrator, for so

  • Tax-Exempt Organization means a "governmental unit," as such term is used in Sections 141 and 148 of the Code.

  • Tax-Exempt means with respect to interest on any obligations of a state or local government, including the Bonds, that such interest is excluded from gross income for federal income tax purposes; provided, however, that such interest may be includable as an item of tax preference or otherwise includable directly or indirectly for purposes of calculating other tax liabilities, including any alternative minimum tax or environmental tax, under the Code.

  • Tax-Exempt Bond means any of a series of the Schwarz Paper Building Redevelopment Project Tax Allocation Bonds of the City, the interest on which is determined by the City to be excludable from gross income for federal income tax purposes.

  • Tax Exempt Obligations means any bond, note or other obligation issued by any person, the interest on which is excludable from gross income for federal income tax purposes.

  • Tax Exemption means any financial assistance granted to a project which is based upon all or a portion of the taxes which would otherwise be levied and assessed against a project but for the involvement of the Agency in such project.

  • Disclosable transaction means any transaction in a security pursuant to which an access person would have a beneficial ownership.

  • U.S. Holder means a beneficial owner of units, Class A ordinary shares or warrants that is for U.S. federal income tax purposes (i) an individual citizen or resident of the United States, (ii) a corporation (or other entity treated as a corporation for U.S. federal income tax purposes) that is created or organized (or treated as created or organized) in or under the laws of the United States, any state thereof or the District of Columbia, (iii) an estate the income of which is subject to U.S. federal income taxation regardless of its source, or (iv) a trust if (A) a court within the United States is able to exercise primary supervision over the administration of the trust and one or more U.S. persons have the authority to control all substantial decisions of the trust, or (B) it has in effect under applicable U.S. Treasury regulations a valid election to be treated as a U.S. person; and

  • Exempt Irish Investor for the present purposes means:

  • Management Investor means any officer, director, employee or other member of the management of the Company or any of its Subsidiaries, or family members or relatives thereof, or trusts or partnerships for the benefit of any of the foregoing, or any of their heirs, executors, successors and legal representatives.

  • Equity Holder means any Person that owns the Equity Interests in any Practice that is a party to any Management Agreement.

  • Non-Exempt Person means any Person other than a Person who is either (i) a U.S. Person or (ii) has on file with the Agent for the relevant year such duly-executed form(s) or statement(s) which may, from time to time, be prescribed by law and which, pursuant to applicable provisions of (A) any income tax treaty between the United States and the country of residence of such Person, (B) the Code or (C) any applicable rules or regulations in effect under clauses (A) or (B) above, permit the Servicer on behalf of the Note Holders to make such payments free of any obligation or liability for withholding.

  • Non-U.S. Holder means a Holder that is not treated as a United States person for U.S. federal income tax purposes as defined under Section 7701(a)(30) of the Internal Revenue Code of 1986, as amended from time to time.

  • Reportable Transaction means a transaction by an Access Person in a Reportable Security.

  • Tax Exemption Certificate means the Tax Exemption Certificate approved under the terms of this Resolution and to be executed by the Treasurer and delivered at the time of issuance and delivery of the Notes.

  • Exempt Person means the Company, any subsidiary of the Company, any employee benefit plan of the Company or any subsidiary of the Company, and any Person organized, appointed or established by the Company for or pursuant to the terms of any such plan.

  • Significant Shareholder means a person or company that has beneficial ownership of, or control or direction over, whether direct or indirect, or a combination of beneficial ownership of, and control or direction over, whether direct or indirect, securities of an issuer carrying more than 10 per cent of the voting rights attached to all the issuer’s outstanding voting securities, excluding, for the purpose of the calculation of the percentage held, any securities held by the person or company as underwriter in the course of a distribution;

  • Nonexempt property means property that is not a principal residence, qualified agricultural property, qualified forest property, supportive housing property, industrial personal property, commercial personal property, or property occupied by a public school academy.

  • parent mixed financial holding company in a Member State means a mixed financial holding company which is not itself a subsidiary of an institution authorised in the same Member State, or of a financial holding company or mixed financial holding company set up in that same Member State;

  • Qualified Institutional Investor (tekikaku kikan xxxxxxx) has the meaning assigned thereto in Article 2, Paragraph 3, item 1 of the Financial Instruments and Exchange Law (kinyu shohin torihiki ho) of Japan (Law No. 25 of 1948), Article 10, Paragraph 1 of the regulations relating to the definitions contained in such Article 2.

  • Investor Affiliate means (i) the Investor or any of his immediate family members, and any such persons’ respective Affiliates and direct and indirect Subsidiaries, (ii) any sponsor, limited partnerships or entities managed or controlled by the Investor or any of his immediate family, or any of such persons’ respective Affiliates and direct or indirect Subsidiaries, (iii) any trust of the Investor or any of his immediate family, or any of such persons’ respective Affiliates and direct or indirect Subsidiaries or any trust in respect of which any such persons is a trustee, (iv) any partnership of which the Investor or any of his immediate family, or any of such persons’ respective Affiliates or direct or indirect Subsidiaries is a partner that is managed or controlled by the Investor, any of his immediate family or any of such persons’ respective Affiliates or direct or indirect Subsidiaries, and (v) any trust, fund or other entity which is managed by, or is under the control of, the Investor or any of his immediate family, or any of such persons’ respective Affiliates or direct or indirect Subsidiaries, but excluding the Issuer or any of its Subsidiaries.

  • Tax-Exempt Bonds means Bonds of a Series the interest on which, in the opinion of Bond Counsel on the date of original issuance thereof, is excludable from gross income for federal income tax purposes.

  • Exempt Transaction means an increase in the percentage of the outstanding shares of Common Stock or the percentage of the combined voting power of the outstanding Voting Stock of the Company beneficially owned by any Person solely as a result of a reduction in the number of shares of Common Stock then outstanding due to the repurchase of Common Stock or Voting Stock by the Company, unless and until such time as (a) such Person or any Affiliate or Associate of such Person shall purchase or otherwise become the Beneficial Owner of additional shares of Common Stock constituting 1% or more of the then outstanding shares of Common Stock or additional Voting Stock representing 1% or more of the combined voting power of the then outstanding Voting Stock, or (b) any other Person (or Persons) who is (or collectively are) the Beneficial Owner of shares of Common Stock constituting 1% or more of the then outstanding shares of Common Stock or Voting Stock representing 1% or more of the combined voting power of the then outstanding Voting Stock shall become an Affiliate or Associate of such Person.

  • parent financial holding company in a Member State means a financial holding company which is not itself a subsidiary of an institution authorised in the same Member State, or of a financial holding company or mixed financial holding company set up in the same Member State;

  • Exempted Transaction means a securities transaction listed in Section D.2. The purchase or sale of a security through an Exempted Transaction generally IS exempted from the prohibition on purchases in Section D.1., and the sale pre-approval requirements in Section D.3., UNLESS otherwise noted in Section VI. An Exempted Transaction generally IS NOT exempted from the general conduct guidelines in Section C, or the reporting requirements in Section E.1.