Tax Equity Partnership definition

Tax Equity Partnership means a special purpose entity in a Partnership Flip Structure whose membership interests are held by a Loan Party or an Excluded Subsidiary, as the managing member, and a Tax Equity Investor or a Subsidiary of such Tax Equity Investor, as the investor member, and whose members are obligated to advance capital contributions to purchase Projects from Sunrun or any of its Subsidiaries in accordance with the related Tax Equity Documents.
Tax Equity Partnership means, with respect to any Project, a limited liability company classified as a partnership for U.S. federal income tax purposes that owns all or any portion of the membership interests of a Project Company or directly owns a Project.
Tax Equity Partnership means Imperial Valley Solar 1 Holdings, LLC.

Examples of Tax Equity Partnership in a sentence

  • Project Company anticipates undergoing a change of control in the form of (i) an acquisition of 100% of the membership interests of Project Company by Affiliate Holdco, and then (ii) an acquisition of 100% of the membership interests of Project Company by Tax Equity Partnership (such acquisitions, the “Changes of Control”), and, in accordance with the terms of Section 8.3 of the Agreements, requests that the Agency consent to such Changes of Control.

  • Within sixty (60) days of the Closing Date, SRP shall deliver to the YieldCo Entities a schedule allocating the Consideration and any other amounts properly treated as consideration for U.S. federal income tax purposes (to the extent known at such time) among the assets of the Tax Equity Partnership in accordance, as applicable, with Sections 755 and 1060 of the Code and the Treasury Regulations thereunder.

  • The Parties agree to cause the Tax Equity Partnership to allocate its tax items for its taxable year which includes the Effective Date based on the “closing of the books” method.


More Definitions of Tax Equity Partnership

Tax Equity Partnership means a special purpose entity whose membership interests are held by any Borrower or an Excluded Subsidiary, as the managing member, and a Tax Equity Investor or a Subsidiary of such Tax Equity Investor, as the investor member, and whose members are obligated to advance capital contributions to purchase PV Systems from any Borrower or its Subsidiaries in accordance with the Partnership Flip Structure. [***] Confidential treatment has been requested for the bracketed portions. The confidential redacted portion has been omitted and filed separately with the Securities and Exchange Commission.
Tax Equity Partnership means a special purpose entity (which may or may not be organized in the form of a partnership) the Equity Interests in which are held by a Manager Subsidiary, as the managing member of such entity, and a Tax Equity Investor or a Subsidiary thereof, as the investor member of such entity, and the members of which are obligated to make cash capital contributions to such entity the proceeds of which are to be used by such entity to purchase Tax Credit Eligible Projects from a Loan Party in accordance with the Partnership Flip Structure.
Tax Equity Partnership means a special purpose entity in a Partnership Flip Structure whose membership interests are held by a Loan Party or an Excluded Subsidiary, as the managing member, and a Tax Equity Investor or a Subsidiary of such Tax Equity Investor, as the investor member, and whose members are obligated to advance capital contributions to purchase Projects from Sunrun or any of its Subsidiaries in accordance with the related Tax Equity Documents. “Taxes” means all present or future taxes, levies, imposts, duties, deductions, withholdings (including backup withholding), assessments, fees or other charges imposed by any Governmental Authority, including any interest, additions to tax or penalties applicable thereto. “Term SOFR” has the meaning provided in the definition ofAdjusted Term SOFR Rate”. “Term SOFR Adjustment” means, for any calculation with respect to a Term SOFR Loan, a percentage per annum as set forth below for the applicable Interest Period therefor: Interest Period Percentage One month 0.11448 % Three months 0.26161% Six months 0.42826% “Term SOFR Administrator” means CBA (or a successor administrator of the forward- looking secured overnight financing rate selected by the Administrative Agent in its reasonable discretion). “Term SOFR Loan” means each Loan bearing interest at a rate based upon the Adjusted Term SOFR Rate. “Third Amendment Effective Date” means February 20, 2024. “Threshold Amount” means [***]. “Total Credit Exposure” means, as to any Lender at any time, the unused Commitments and Revolving Exposure of such Lender at such time. “Total Debt” means, as of the last day of any Measurement Period, (a) the aggregate amount of all senior secured Indebtedness of the Loan Parties less (b) the Quarter-End Liquidity, in each case, as of the last day of such Measurement Period; provided that in no event shall Total Debt be less than zero. “Total Outstandings” means the aggregate Outstanding Amount of all Revolving Loans and L/C Obligations. “Tranching” means the sale, lease, assignment, contribution or other transfer of Permitted Assets by the Borrower or its Subsidiaries to an Excluded Subsidiary or Tax Equity Investor in
Tax Equity Partnership is defined in the Recitals.
Tax Equity Partnership means a tax equity investment vehicle formed by a Subsidiary of the Company and a third-party investor to whom certain tax benefits associated with the ownership of solar energy systems or energy storage systems are transferred or allocated.

Related to Tax Equity Partnership

  • Foreign limited liability partnership means a partnership that:

  • Limited liability partnership or “LLP” shall mean a Company governed by Limited Liability Partnership Act 2008 or as amended;

  • General partnership means an organization formed under chapters 45-13 through 45-21.

  • Foreign limited partnership means a partnership formed under laws other than of this state and having as partners one or more general partners and one or more limited partners.

  • GP means Gottbetter & Partners, LLP.

  • Foreign limited liability limited partnership means a foreign limited partnership whose general partners have limited liability for the obligations of the foreign limited partnership under a provision similar to section 488.404, subsection 3.

  • Community Contribution Company means a corporation formed under the laws of British Columbia that includes in its articles the following statement:

  • Public-private partnership means an arrangement or agreement, occurring on or after January 1, 2017, between a procurement unit and one or more contractors to provide for a public need through the development or operation of a project in which the contractor or

  • REIT means a “real estate investment trust” under Sections 856 through 860 of the Code.

  • Initial Limited Partners means the Organizational Limited Partner (with respect to the Common Units and Subordinated Units received by it as described in Section 5.1), the General Partner (with respect to the Incentive Distribution Rights received by it as described in Section 5.1) and the Underwriters, in each case upon being admitted to the Partnership in accordance with Section 10.1.

  • MLP Partnership Agreement means the Amended and Restated Agreement of Limited Partnership of the MLP, as amended or restated from time to time.

  • Limited partnership means a limited partnership registered or formed under any law in force in Singapore or elsewhere;

  • Borrower Partnership Agreement means the Limited Partnership Agreement of the Borrower dated as of January 17, 2014 as such agreement may be amended, restated, modified or supplemented from time to time with the consent of the Administrative Agent or as permitted under Section 10.10.

  • Domestic partnership means an association of two or more persons to carry on as co-owners a

  • mixed financial holding company means a mixed financial holding company as defined in point (21) of Article 4(1) of Regulation (EU) No 575/2013;

  • Public-private partnership agreement means an agreement

  • Member-managed limited liability company means a limited liability company that is not a manager-managed limited liability company.

  • Manager-managed limited liability company means a limited liability company that is managed by

  • Series Company refers to the form of registered open-end investment company described in Section 18(f)(2) of the 1940 Act or in any successor statutory provision;

  • Surviving Partnership has the meaning set forth in Section 11.2.B(ii) hereof.

  • Operating Partnership has the meaning set forth in the preamble.

  • Initial Limited Partner has the meaning set forth in the Preamble.

  • Subsidiary Partnership means any partnership of which the partnership interests therein are owned by the General Partner or a direct or indirect subsidiary of the General Partner.

  • LP means the aggregate quantity of Lost Production during such Month (expressed in MWh) and

  • Local Distribution Company or “LDC” means a Person licensed by the OEB as a “Distributor” in connection with a Distribution System.

  • Holdco has the meaning set forth in the Preamble.