Distribution Tax definition

Distribution Tax means (i) any Tax, calculated without regard to any Tax Benefit Attributes of the Remainco Group, required to be paid by or imposed on any Remainco Group member resulting from, or arising in connection with, the failure of any of the Internal Distributions, the New News Corporation Contribution or the Distribution to qualify for the Intended Tax Treatment, including by reason of the application of Section 355(e) of the Code to the Distribution, and (ii) any and all losses and liabilities relating to or arising from claims of lawsuits by stockholders of Remainco or stockholders of New News Corporation resulting from (A) the failure of the Distribution to be tax-free to such stockholders under Section 355 of the Code (except with respect to cash received in lieu of fractional shares of New News Corporation stock) or (B) the Distribution and the Restructuring not being treated, for U.S. federal income tax purposes, in accordance with the Intended Tax Treatment;
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Distribution Tax means the Taxes described in Section 2.5(a)(ii).
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Distribution Tax means any liability for any Tax (including any Tax of any shareholder of IR or Allegion) that arises directly or indirectly as a result of (i) the Distribution or any of the Internal Distributions failing to qualify (in whole or in part) under Section 355 of the Code, (ii) the stock of Allegion or any Allegion Subsidiary distributed in the Distribution or any of the Internal Distributions, as applicable, failing to be treated as qualified property pursuant to Section 355(e) of the Code, (iii) any stamp, duty, sales, use, transfer or similar Tax imposed as a result of the transactions described in the Ruling or that are part of the Internal Reorganization, (iv) the Distribution failing to qualify, in whole or in part, as tax-free under the applicable provisions of Irish tax law described in the Irish Revenue Clearances and related legal opinions, (v) the implementation of the Canadian Butterfly Transactions, including any preliminary transactions or steps taken in connection with the implementation of the Canadian Butterfly Transactions, or (vi) the failure, in whole or in part, of any of the transactions described in the Ruling or that are part of the Internal Reorganization to qualify for the expected Tax treatment as set forth in the Ruling, the Tax Opinions, or any Tax Return filed by any member of the IR Group, to the extent related to the Distribution or the Internal Reorganization, as applicable.
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Examples of Distribution Tax in a sentence

  • The Distribution Tax Opinion shall be based upon the IRS Ruling, any other rulings issued by the IRS in connection with the Ruling Request, and customary representations and covenants, including those contained in certificates of Verizon, Spinco, the Company and others, reasonably satisfactory in form and substance to Verizon Tax Counsel (such representations and covenants, the “Distribution Tax Representations”).

  • Each of Verizon, Spinco and the Company agrees to use its commercially reasonable efforts to obtain the Distribution Tax Opinion.

  • If you take a Refunded Distribution, any refunds received from an Eligible Educational Institution will not be subject to federal or New Mexico state income tax or the Distribution Tax.

  • To avoid federal income tax consequences and the Distribution Tax, you must contribute an indirect rollover within 60 days of the distribution.

  • If the distribution is subject to a Distribution Tax, the Distribution Tax is applied to the earnings portion.

  • The distributions discussed in this paragraph are not subject to the Distribution Tax.

  • A distribution of amounts in your Account, if not paid to a beneficiary of the Beneficiary or the Beneficiary’s estate, may constitute a Non-Qualified Distribution, subject to federal and applicable state income taxes at the distributee’s tax rate and the Distribution Tax.

  • ABLE Rollover Distributions may be subject to certain state taxes but are generally exempt from federal income taxes and the Distribution Tax.

  • A distribution due to the Disability of the Beneficiary will not be subject to the Distribution Tax, but earnings will be subject to federal and any applicable state income tax at your tax rate.

  • Where a distribution is placed in a Qualified ABLE Program account within 60 days of the distribution date, you may avoid incurring federal income tax or a Distribution Tax if the transfer is for the same Beneficiary or for a Member of the Family of the Beneficiary.


More Definitions of Distribution Tax

Distribution Tax means any registration, transfer or Income Taxes (including any Taxes incurred with regard to Section 311(b) of the Code) directly resulting from the Distribution imposed upon WCA or any member of the WCA Group; provided that such term shall not refer to the collateral Tax effects of the Distribution (including with regard to the Tax basis of assets).
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Distribution Tax means (i) any Tax, calculated without regard to any Tax Benefit Attributes of the MII Group, required to be paid by or imposed on any MII Group member resulting from, or arising in connection with, the failure of the MVWC Contribution or the Distribution to qualify for the Intended Tax Treatment, including by reason of the application of Section 355(e) of the Code to the Distribution, and (ii) any and all losses and liabilities relating to or arising from claims of lawsuits by stockholders of MII resulting from the failure of the Distribution to be tax-free to such stockholders under Section 355 of the Code (except with respect to cash received in lieu of fractional shares of MVWC Common Stock);
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Distribution Tax means any federal or state tax imposed on a Person as a result of a Failure, together with any related interest, penalties or additions to tax.
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Distribution Tax means any Tax required to be paid by or imposed on any Party or any of its Subsidiaries resulting from, or directly arising in connection with, the failure of the Contribution, the Debt Exchange, the Debt Repayment, any Internal Spin-Off or the External Split-Off to qualify for the Intended Tax Treatment;
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Distribution Tax means any liability for any Tax (including any Tax of any shareholder of IR or Allegion) that arises directly or indirectly as a result of (i) the Distribution or any of the Internal Distributions failing to qualify (in whole or in part) under Section 355 of the Code, (ii) the stock of Allegion or any Allegion Subsidiary distributed in the Distribution or any of the Internal Distributions, as applicable, failing to be treated as qualified property pursuant to Section 355(e) of the Code, (iii) any stamp, duty, sales, use, transfer or similar Tax imposed as a result of the transactions described in the Ruling or Separation Agreement, (iv) the Distribution failing to qualify, in whole or in part, as tax-free under the applicable provisions of Irish tax law described in the Irish Revenue Clearances and related legal opinions, (v) the Canadian Butterfly Transactions failing to qualify for Canadian Tax-Free Status (if IR intends that the Canadian Butterfly Transactions qualify for Canadian Tax-Free Status) or (vi) the failure, in whole or in part, of any of the transactions described in the Ruling or Separation Agreement (including, for the avoidance of doubt, any transaction that is part of the Internal Reorganization) to qualify for the expected Tax treatment as set forth in the Ruling, the Tax Opinions, or any Tax Return filed by any member of the IR Group, to the extent related to the Distribution or the Internal Reorganization, as applicable.
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Distribution Tax means (i) any Tax, calculated without regard to any Tax Benefit Attributes of the Remainco Group, required to be paid by or imposed on any Remainco Group member resulting from, or arising in connection with, the failure of any of the Internal Distributions, the New News Corporation
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Related to Distribution Tax

  • Distribution Taxes means any Taxes incurred solely as a result of the failure of the Intended Tax Treatment of the Restructuring, the Contribution or the Distribution.

  • Post-Distribution Tax Period means a Tax period beginning and ending after the Distribution Date.

  • Pre-Distribution Tax Period means any taxable period (or portion thereof) that ends on or before the Distribution Date.

  • Distribution Tariff means the Distribution Tariff prepared by the Company and approved by the Commission on an interim or final basis, as the case may be;

  • non-taxable territory means the territory which is outside the taxable territory;

  • distribution losses means energy losses that result from the interaction of intrinsic characteristics of the distribution network such as electrical resistance with network voltages and current flows;

  • Hypothetical Tax Liability means, with respect to any Taxable Year, the liability for Taxes of the Corporation (or the Partnerships, but only with respect to Taxes imposed on the Partnerships and allocable to the Corporation) using the same methods, elections, conventions and similar practices used on the relevant Corporation Return but using the Non-Stepped Up Tax Basis instead of the tax basis reflecting the Basis Adjustments of the Adjusted Assets and excluding any deduction attributable to Imputed Interest.

  • Transaction Taxes has the meaning set forth in Section 6.01.

  • Transaction Tax Deductions means any Tax deductions relating to (i) any pay down or satisfaction of Company Indebtedness or other Indebtedness, (ii) the payment or incurrence of any Transaction Expenses or Transaction Bonus Payments and (iii) any other deductible payments attributable to the Contemplated Transactions economically borne by the Seller. For this purpose, any success-based fees shall be treated as deductible in accordance with Rev. Proc. 2011-29.

  • Income Taxes means any taxes measured, in whole or in part, by net or gross income or profits together with any interest, penalties or additions to tax.

  • Net Taxable Income has the meaning set forth in Section 4.01(b)(i).

  • Non-Income Tax Return means any Tax Return relating to any Tax other than an Income Tax.

  • REMIC II Interest Loss Allocation Amount With respect to any Distribution Date, an amount equal to (a) the product of (i) 50% of the aggregate Stated Principal Balance of the Mortgage Loans and REO Properties then outstanding and (ii) the REMIC II Remittance Rate for REMIC II Regular Interest AA minus the Marker Rate, divided by (b) 12.

  • REMIC 2 Interest Loss Allocation Amount With respect to any Distribution Date, an amount equal to (a) the product of (i) the aggregate Stated Principal Balance of the Mortgage Loans and related REO Properties then outstanding and (ii) the Uncertificated REMIC 2 Pass-Through Rate for REMIC 2 Regular Interest LTAA minus the Marker Rate, divided by (b) 12.

  • Pre-Tax Contributions means, for any Participant, the aggregate of the Participant's Basic Pre-Tax Contributions and Supplemental Pre-Tax Contributions contributed to the applicable Pre-Tax Contribution Account.

  • REMIC I Interest Loss Allocation Amount With respect to any Distribution Date, an amount equal to (a) the product of (i) the aggregate Stated Principal Balance of the Mortgage Loans and REO Properties then outstanding and (ii) the REMIC I Remittance Rate for REMIC I Regular Interest I-LTAA minus the Marker Rate, divided by (b) 12.

  • Income Tax Return means any return, declaration, report, claim for refund, or information return or statement relating to Income Taxes, including any schedule or attachment thereto, and including any amendment thereof.

  • Non-Income Tax means any Tax other than an Income Tax.

  • Production Tax Credit or “PTC” means the tax credit for electricity produced from certain renewable generation resources described in Section 45 of the Internal Revenue Code of 1986, as it may be amended or supplemented from time to time.

  • Pre-Tax Income means income, as determined by GAAP, prior to deduction of the Bonus Pool (as hereinafter defined) and income taxes, and if applicable, after the deduction of any bonus pool of a future officer bonus plan adopted by the Company relating to an applicable Award Year and adjustments approved by the Board as described herein.

  • Straddle Tax Period means any taxable period beginning on or before and ending after the Closing Date.

  • Income Tax means any federal, state, local or foreign Tax (a) based upon, measured by or calculated with respect to net income, profits or receipts (including, without limitation, capital gains Taxes and minimum Taxes) or (b) based upon, measured by or calculated with respect to multiple bases (including, without limitation, corporate franchise taxes) if one or more of the bases on which such Tax may be based, measured by or calculated with respect to, is described in clause (a), in each case together with any interest, penalties, or additions to such Tax.

  • Separate Return means (a) in the case of any Tax Return of any member of the SpinCo Group (including any consolidated, combined or unitary return), any such Tax Return that does not include any member of the Parent Group and (b) in the case of any Tax Return of any member of the Parent Group (including any consolidated, combined or unitary return), any such Tax Return that does not include any member of the SpinCo Group.

  • Net Tax Benefit has the meaning set forth in Section 3.1(b) of this Agreement.

  • Non-Income Taxes means any Taxes other than Income Taxes.

  • Taxable income means, in the case of an individual, federal adjusted gross income determined without regard to 26 U.S.C. § 168(k) and: