United States Federal Tax definition

United States Federal Tax means any one of the foregoing United States Federal Taxes.
Sample 1Sample 2Sample 3
United States Federal Tax means any one of the foregoing United States Federal Taxes. Any capitalized term not otherwise defined in this Agreement shall have the meaning ascribed to it in the Distribution Agreement. ARTICLE II ---------- ALLOCATION OF TAX LIABILITIES -----------------------------
Sample 1Sample 2

Examples of United States Federal Tax in a sentence

  • The Company makes this representation only in connection with the discussion in the Prospectus under the heading “Material United States Federal Tax Considerations”.

  • The statements in each of the Registration Statement, the Time of Sale Information and the Prospectus under the captions “Description of Notes” and “Material United States Federal Tax Considerations,” in each case insofar as such statements constitute a summary of the legal matters or documents referred to therein, fairly present and summarize, in all material respects, the matters referred to therein.

  • The confirmation set forth in this letter (a) deals only with the specific legal issue or issues it explicitly addresses and does not address other matter and (b) does not address the effect of any law (including, but not limited to, public policy reflected therein) other than United States Federal Tax Law.

  • The statements in the General Disclosure Package and the Final Prospectus under the headings “Material United States Federal Tax Considerations”, and “Description of the Notes” insofar as such statements summarize legal matters, agreements, documents or proceedings discussed therein fairly present and summarize the matters referred to therein.

  • Based upon and subject to the foregoing, we confirm that the discussion in the Registration Statement under the caption "United States Federal Tax Consequences," to the extent it consists of statements of law and legal conclusions, and subject to the limitations and qualifications set forth therein, constitutes our opinion as to the material U.S. federal tax consequences that apply under currently applicable law to the purchase, ownership and disposition of the Shares.

  • We note that (a) United States Federal Tax Law is subject to change at any time possibly with retroactive effect, (b) there is no direct legal authority addressing certain of the issues covered by the discussion of United States Federal Tax Law in the Registration Statement under the heading “TAXATION” and (c) there can be no assurance that any opinion expressed in such discussion will be accepted by the I.R.S. or a court.

  • We hereby consent to the filing of this opinion as an exhibit to the Registration Statement and to all references to this firm under the headings "Summary -- Federal Income Tax Consequences", "Risk Factors -- Taxability of Warrant Issuance", "The Transaction -- Federal Income Tax Consequences" in the Proxy Statement and Prospectus and "Certain Federal Income Tax Consequences" and "Certain United States Federal Tax Considerations for Non-U.S. Holders of Class B Shares" in the Warrant Prospectus.

  • Debtor shall not change its name, identity, jurisdiction of organization or corporate structure in any manner that might make any Financing Statement filed in connection with this Agreement misleading or its United States Federal Tax I.D. Number, in each case unless Debtor shall have given Secured Party 30 days prior written notice thereof and shall have taken all action deemed necessary or appropriate by Secured Party to protect its Liens and the perfection and priority thereof.

  • The statements in the General Disclosure Package and the Final Prospectus under the headings “Certain Material United States Federal Tax Considerations”, and “Description of the Notes” insofar as such statements summarize legal matters, agreements, documents or proceedings discussed therein fairly present and summarize the matters referred to therein.

  • The statements in the General Disclosure Package and the Final Prospectus under the headings “Description of the Notes”, “Description of Debt Securities” and “Material United States Federal Tax Consequences”, insofar as such statements summarize legal matters, agreements, documents or proceedings discussed therein, are accurate and fair summaries of such legal matters, agreements, documents or proceedings in all material respects and present the information required to be shown therein.

Related to United States Federal Tax

  • Federal Tax means any Tax imposed under Subtitle A of the Code.

  • United States Citizen shall have the meaning set forth in Section 3.02.

  • Federal Tax Certificate means the Issuer's Federal Tax Certificate dated as of the Issue Date, as the same may be amended or supplemented in accordance with the provisions thereof.

  • United States Forces Korea (USFK) means the subordinate unified command through which US forces would be sent to the Combined Forces Command fighting components.

  • United States Tax Person A citizen or resident of the United States, a corporation, partnership or other entity created or organized in, or under the laws of, the United States, any State thereof or the District of Columbia, an estate whose income from sources without the United States is includible in gross income for United States federal income tax purposes regardless of its source or a trust if a court within the United States is able to exercise primary supervision over the administration of the trust and one or more United States Tax Persons have the authority to control all substantial decisions of the trust, all within the meaning of Section 7701(a)(30) of the Code (or, to the extent provided in the applicable Treasury Regulations, certain trusts in existence on August 20, 1996 that have elected to be treated as United States Tax Persons).

  • Citizen of the United States has the meaning specified for such term in Section 40102(a)(15) of Title 49 of the United States Code or any similar legislation of the United States enacted in substitution or replacement therefor.

  • All applicable Federal, State, and local taxes and duties means all taxes and duties, in effect on the contract date, that the taxing authority is imposing and collecting on the transactions or property covered by this contract.

  • United States shareholder means, with respect to any foreign corporation, a United States person who owns, or is considered as owning, 10 percent or more of the total combined voting power of all classes of stock entitled to vote of such foreign corporation.

  • United States Bankruptcy Code means the Bankruptcy Reform Act of 1978, as amended and as codified in Title 11 of the United States Code, as amended from time to time hereafter, or any successor federal bankruptcy law.

  • Non-United States Tax Person Any Person other than a United States Tax Person.

  • United States and “U.S.” mean the United States of America.

  • United States Alien means any Person who, for United States Federal income tax purposes, is a foreign corporation, a non-resident alien individual, a non-resident alien fiduciary of a foreign estate or trust, or a foreign partnership one or more of the members of which is, for United States Federal income tax purposes, a foreign corporation, a non-resident alien individual or a non-resident alien fiduciary of a foreign estate or trust.

  • Assumed State and Local Tax Rate means the tax rate equal to the sum of the products of (x) the Corporation’s income tax apportionment factor for each state and local jurisdiction in which the Corporation files income or franchise tax returns for the relevant Taxable Year and (y) the highest corporate income and franchise tax rate in effect for such Taxable Year for each such state and local jurisdiction in which the Corporation files income tax returns for each relevant Taxable Year.

  • Qualified United States financial institution means an institution that:

  • State Income Tax means any Tax imposed by any State of the United States (or by any political subdivision of any such State) or the District of Columbia, or any city or municipality located therein, which is imposed on or measured by net income, including state and local franchise or similar Taxes measured by net income, and any interest, penalties, additions to tax, or additional amounts in respect of the foregoing.

  • Consolidated federal income tax return means a consolidated return filed for federal income tax purposes pursuant to section 1501 of the Internal Revenue Code.

  • Income Tax means any federal, state, local, or foreign income tax, including any interest, penalty, or addition thereto, whether disputed or not.

  • Federal Income Tax means any Tax imposed by Subtitle A of the Code, and any interest, penalties, additions to tax, or additional amounts in respect of the foregoing.

  • Outside the United States means a location outside the geographic boundaries of the United States, Puerto Rico, the United States Virgin Islands, and any territory, insular possession, or other location subject to the jurisdiction of the United States.

  • Appropriate Federal Banking Agency means the “appropriate Federal banking agency” with respect to the Corporation as defined in Section 3(q) of the Federal Deposit Insurance Act (12 U.S.C. Section 1813(q)), or any successor provision.

  • foreign tax means any Foreign Income Taxes or Foreign Other Taxes.

  • Disregarded Entity means a single member limited liability company, a qualifying subchapter S subsidiary, or another entity if the company, subsidiary, or entity is a disregarded entity for federal income tax purposes.

  • Disqualified Non-United States Tax Person With respect to any Class R Certificate, any Non-United States Tax Person or agent thereof other than: (1) a Non-United States Tax Person that (a) holds such Class R Certificate and, for purposes of Treasury Regulations Section 1.860G-3(a)(3), is subject to tax under Section 882 of the Code, (b) certifies that it understands that, for purposes of Treasury Regulations Section 1.860E-1(c)(4)(ii), as a holder of such Class R Certificate for United States federal income tax purposes, it may incur tax liabilities in excess of any cash flows generated by such Class R Certificate and intends to pay taxes associated with holding such Class R Certificate, and (c) has furnished the Transferor, the Trustee, the Certificate Administrator and the Tax Administrator with an effective IRS Form W-8ECI or successor form and has agreed to update such form as required under the applicable Treasury regulations; or (2) a Non-United States Tax Person that has delivered to the Transferor, the Trustee, the Certificate Administrator and the Tax Administrator an opinion of nationally recognized tax counsel to the effect that (x) the Transfer of such Class R Certificate to it is in accordance with the requirements of the Code and the regulations promulgated thereunder and (y) such Transfer of such Class R Certificate will not be disregarded for United States federal income tax purposes.