TEFRA Rules definition
Examples of TEFRA Rules in a sentence
Regulation S, Category 2, TEFRA D Rules apply, unless TEFRA C Rules are specified as applicable in the applicable Final Terms or unless TEFRA Rules are not applicable.
The General Partner is hereby designated as the “tax matters partner” of the Partnership, as such term is defined in Section 6231 of the TEFRA Rules with respect to all taxable years to which the TEFRA Rules apply (the “Tax Matters Partner”).
The applicable Final Terms will identify whether TEFRA D Rules or TEFRA C Rules apply or whether the TEFRA Rules are not applicable.
Regulation S, Category 2, TEFRA D Rules apply unless TEFRA C Rules are specified as applicable in the applicable Final Terms or unless TEFRA Rules are not applicable.
The General Partner shall be the “tax matters partner” of the Partnership for purposes of the TEFRA Rules and the “partnership representative” of the Partnership for purposes of the BBA Rules (collectively, the “tax matters partner”) for federal income tax purposes.
The Tax Matters Member will represent the Company in any audits, disputes or controversies or proceedings under the TEFRA Rules; provided, however, that the Tax Matters Member shall keep the Board of Managers informed as to all material developments with respect to such audits, disputes or controversies and shall not have any right to settle or compromise any such audits, disputes, controversies or proceedings without approval of the Board of Managers.
Regulation S, Category 2, TEFRA D Rules apply, unless TEFRA C Rules are specified as applicable in the applicable Final Terms or Pricing Supplement or unless TEFRA Rules are not applicable.
With respect to Partnership tax years beginning before January 1, 2018, pursuant to Section 6230(e) (under the TEFRA Rules) of the Code, upon receipt of notice from the IRS of the beginning of an administrative proceeding with respect to the Partnership, the tax matters partner shall furnish the IRS with the name, address and profit interest of each of the Limited Partners and Assignees; provided, however, that such information is provided to the Partnership by the Limited Partners and Assignees.
Regulation S, Category 2, TEFRA D Rules apply, unless TEFRA C Rules are specified as applicable in the Final Terms or unless TEFRA Rules are not applicable.
The Manager is hereby designated (i) with respect to all taxable years to which the TEFRA Rules apply, the “tax matters partner” of the Company, as provided under Section 6231 of the TEFRA Rules and the Regulations thereunder (the “Tax Matters Member”) and (ii) with respect to all taxable years to which the BBA Rules apply, the “partnership representative” of the Company, as provided under Section 6223 of the BBA Rules (the “Partnership Representative”).