Transaction Deduction means any deduction permitted for income Tax purposes, to the extent “more likely than not” deductible (or at a higher confidence level), attributable to any payments (or deemed payments) of the Transaction Expenses made before, on, or after the Closing Date.
Transaction Deduction means all items of loss or deduction for applicable income Tax purposes resulting from or attributable to: (i) items included in Closing Date Net Working Capital, Closing Date Indebtedness, or Holder Expenses, (ii) any compensatory payments made pursuant to this Agreement (including, subject to Section 7.5(l), the portion of the Bonus Agreement Payment that is payable upon Closing and payments in respect of Phantom Units, including the cost recharge for amounts payable with respect to Phantom Units held by employees of A-1 Engineering Korea, Inc., pursuant to any transfer pricing agreement with A-1 Engineering Korea, Inc.), and (iii) any fees, expenses, premiums and penalties with respect to the prepayment of debt and the write-off or acceleration of the amortization of deferred financing.
Transaction Deduction means, without duplication, any deduction permitted for income Tax purposes attributable to (i) any payments (or deemed payments) of Transaction Expenses; (ii) the payment of the Merger Consideration with respect to the Options (and related employer portion of employment Taxes); and (iii) the exercise of an Option between (and including) the date hereof and the Closing Date (and related employer portion of employment Taxes).
Examples of Transaction Deduction in a sentence
That, to the extent permitted by law, any income Tax deduction with respect to any Transaction Deduction paid or accrued on or prior to the Closing Date shall be deducted on the Equity Seller’s IRS Form 1120S for the Tax year that includes the Closing Date.
To the extent the Transaction Deduction benefits are not used in any Pre-Closing Tax Period, they will be carried forward and will be treated as the first items of loss offsets for future years.
Transaction Deduction rate/charges along with applicable taxes should hit to the customer (not to the DGH) at the time of making the payment.
More Definitions of Transaction Deduction
Transaction Deduction means any deduction permitted for income Tax purposes attributable to any payments (or deemed payments) of (i) Transaction Expenses or other similar expenses paid on, prior to or after the Closing Date or included in the computation of the Working Capital; (ii) the payment of the Merger Consideration with respect to the Options (and related employer portion of employment Taxes); (iii) the exercise of an Option between (and including) the date hereof and the Closing Date (and related employer portion of employment Taxes); (iv) the vesting of any Securities in connection with the Transaction; and (v) any fees, expenses and interest (including amounts treated as interest for income Tax purposes) that were included in the computation of the Working Capital.
Transaction Deduction means all items of loss or deduction for applicable income Tax purposes resulting from or attributable to: (a) items included in Current Liabilities, Debt, or Transaction Expenses, (b) any compensatory payments made pursuant to this Agreement and (c) any fees, expenses, premiums and penalties with respect to the prepayment of debt and the write- off or acceleration of the amortization of deferred financing.
Transaction Deduction means the sum, without duplication, of the following, in each case to the extent properly deductible for U.S. federal income tax purposes: (a) any sale bonuses or other compensatory payments made in connection with the Merger (including the Company portion of any employment Taxes borne by the Indemnitors); and (b) to the extent not included in the foregoing clause “(a),” any and all payments of Company Transaction Expenses and Indebtedness as contemplated by this Agreement.
Transaction Deduction means all items of loss or deduction for applicable income Tax purposes resulting from or attributable to: (a) the payment of any stay, sale, retention, transaction or change of control bonuses, severance payments or other compensatory payments made in connection with the Transactions on or about the Closing Date; (b) Transaction Expenses; (c) any fees, expenses, premiums and penalties with respect to the prepayment of debt and the write-off of the amortization of deferred financing, in each case with respect to Indebtedness repaid at Closing; or (d) any liabilities included in Net Working Capital or Indebtedness.
Transaction Deduction means all items of loss or deduction for applicable income Tax purposes resulting from or attributable to: (i) items included in Net Working Capital, Liabilities, or Transaction Expenses, (ii) any bonuses, option exercises or cashouts or other compensatory payments made in connection with the transactions contemplated by this Agreement, in each case payable on or about the Closing Date (but not after the next regularly scheduled payroll date immediately following the Closing Date) in connection with the transactions contemplated by this Agreement, including any payroll or similar taxes related to such payment, (iii) and any fees, expenses, premiums and penalties with respect to the prepayment of debt and the write-off or acceleration of the amortization of deferred financing on or about the Closing Date in connection with the transactions contemplated by this Agreement.
Transaction Deduction means the sum of (a) any all deductible amounts incurred in connection with compensation costs resulting from the consummation of the transaction contemplated by this Agreement; (b) any and all deductible amounts incurred in connection with the retirement of any debt or obligation of the Company or its Subsidiaries as contemplated by this Agreement; (c) any and all deductible payments of Transaction Expenses as contemplated by this Agreement; provided that for purposes of this Agreement, the parties agree that 70% of any success-based fees paid by the Company or any of the Company’s Subsidiaries shall be deductible under Rev. Proc. 2011-29.
Transaction Deduction means any deduction permitted for U.S. federal income Tax purposes attributable to any payments (or deemed payments) of (i) Transaction Expenses paid on, prior to or after the Closing Date or included in the computation of the Working Capital; (ii) the payment of the Merger Consideration with respect to the Options (and related employer portion of employment Taxes); (iii) the exercise of an Option between (and including) the date hereof and the Closing Date (and related employer portion of employment Taxes); (iv) the vesting of any Shares in connection with the Transaction; and