Transition Tax definition

Transition Tax means any Tax resulting from the treatment of accumulated post-1986 deferred foreign income as Subpart F income pursuant to Section 965 of the Code. “Treasury Regulations” has the meaning ascribed to such term in the second WHEREAS clause hereof.
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Transition Tax means any one-time increase in Rhode Island income tax arising from the recognition of 965 Income.
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Transition Tax means any Tax resulting from the treatment of accumulated post-1986 deferred foreign income as Subpart F income pursuant to Section 965 of the Code.
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Examples of Transition Tax in a sentence

  • The tax year in which the Facility achieves commercial operation also referred to as "the Transition Tax Year," shall be the first tax year covered by this Agreement.

  • Dell Technologies agrees to pay Pivotal a one-time, risk adjusted payment of $26.5 million in complete settlement of both the FY2018 federal return Transition Tax benefit and any future tax expense attributable to the inclusion in taxable income of any foreign Sec.

  • Pivotal relinquishes any current or future claim to benefits Dell Technologies received from the inclusion of Pivotal foreign deficits or foreign tax credits in the 2018 Transition Tax calculation.

  • Dell assumes the risk and/or benefit of any audit adjustments to the Transition Tax calculation in the US federal return, including the US Transition Tax effect of any foreign audit adjustments.

  • This Letter Agreement contains the entire agreement among the parties hereto with respect to the subject matter hereof and supersedes any prior tax sharing agreements between Dell Technologies (or any Dell Technologies Affiliate) and VMware (or any VMware Affiliate) with respect to the Section 965 Transition Tax, and such prior tax sharing agreements shall have no further force and effect.

  • Other than the Transition Tax Year Payment, which shall be made as set forth in Section 3 above, the Developer shall make the PILOT payments due hereunder for any given tax year in the Operating Term to the Town in two equal installments, at the Town Tax Collector's office, on July 1st and December 1st.

  • Recognizing that construction of the Facility may not have commenced (or that if construction has commenced the Facility is likely to be only partially constructed) as of April I of said Transition Tax Year.

  • Dell assumes the risk and/or benefit which may arise out of future clarifications or corrections to the Transition Tax calculation and/ or the carryforward effects on future returns of the Dell consolidated returns.

  • To the extent not already taken into account under the TSA, a reduction for an any attributes generated by the VMware group for which an election under Section 965 is made to apply such benefit to the Section 965 Transition Tax.

  • Other than the Transition Tax Year Payment, which shall be made as set forth in Section 3 above, Developer shall make the PILOT payments due hereunder for any given tax year in the Operating Term to the Town in two equal installments, at the Town Tax Collector's office, on July 1st and December 1st.