Sentences with phrase «us federal income tax purposes»

Section 162 (m) of the Internal Revenue Code imposes limitations on the deductibility for corporate federal income tax purposes of remuneration in excess of $ 1 million paid to the chief executive officer, chief financial officer and each of the three next most highly compensated executive officers of a public company.

You were married in a state that recognizes same - sex marriage, you are considered «married» for Federal income tax purposes.

Persons that for U.S. federal income tax purposes are treated as a partner in a partnership holding shares of our Class A common stock should consult their tax advisors.

If an entity or arrangement treated as a partnership for U.S. federal income tax purposes holds shares of our common stock, the tax treatment of a person treated as a partner generally will depend on the status of the partner and the activities of the partnership.

Our post-offering organizational structure will allow the Continuing LLC Owners to retain their equity ownership in Desert Newco, an entity that is classified as a partnership for U.S. federal income tax purposes, in the form of LLC Units.

They are for federal income tax purposes.

The spin - off is taxable for U.S. federal income tax purposes.

SSE Holdings will continue to be treated as a partnership for U.S. federal income tax purposes and, as such, will not be subject to any entity - level U.S. federal income tax.

as a transaction that is generally tax - free, for U.S. federal income tax purposes, under Sections 355 and 368 (a)(1)(D) of the Code.

If we pay distributions on our common stock, those distributions generally will constitute dividends for U.S. federal income tax purposes to the extent paid from our current or accumulated earnings and profits, as determined under U.S. federal income tax principles.

It does not discuss all aspects of U.S. federal income taxation that may be relevant to particular holders in light of their particular circumstances or to holders subject to special rules under the Code (including, but not limited to, insurance companies, tax - exempt organizations, financial institutions, broker - dealers, partners in partnerships (or entities or arrangements treated as partnerships for U.S. federal income tax purposes) that hold HP Co. common stock, pass - through entities (or investors therein), traders in securities who elect to apply a mark - to - market method of accounting, stockholders who hold HP Co. common stock as part of a «hedge,» «straddle,» «conversion,» «synthetic security,» «integrated investment» or «constructive sale transaction,» individuals who receive HP Co. or Hewlett Packard Enterprise common stock upon the exercise of employee stock options or otherwise as compensation, holders who are liable for the alternative minimum tax or any holders who actually or constructively own 5 % or more of HP Co. common stock).

SCH was treated as a partnership for U.S. federal income tax purposes, and as such, was not subject to any U.S. federal entity - level income taxes.

As discussed above, notwithstanding receipt by HP Co. of a private letter ruling from the IRS and / or opinions of counsel and other external tax advisors, the IRS could assert that the distribution does not qualify for tax - free treatment for U.S. federal income tax purposes.

Accordingly, notwithstanding receipt by HP Co. of the IRS private letter ruling and the tax opinions referred to above, the IRS could assert that the distribution and / or certain related transactions do not qualify for tax - free treatment for U.S. federal income tax purposes.

Accordingly, notwithstanding receipt by HP Co. of the IRS private letter ruling and the tax opinions referred to above, there can be no assurance that the IRS will not assert that the distribution and / or certain related transactions do not qualify for tax - free treatment for U.S. federal income tax purposes or that a court would not sustain such a challenge.

It is a condition to the distribution that HP Co. receive (i) a private letter ruling from the IRS and / or one or more opinions from its external tax advisors, in each case, satisfactory to HP Co.'s board of directors, regarding certain U.S. federal income tax matters relating to the separation and related transactions, and (ii) an opinion of each of Wachtell, Lipton, Rosen & Katz and Skadden, Arps, Slate, Meagher & Flom LLP, satisfactory to HP Co.'s board of directors, regarding the qualification of the distribution, together with certain related transactions, as a transaction that is generally tax - free, for U.S. federal income tax purposes, under Sections 355 and 368 (a)(1)(D) of the Code.

We believe that the Continuing LLC Owners generally find it advantageous to hold their equity interests in an entity that is not taxable as a corporation for U.S. federal income tax purposes.

Accordingly, notwithstanding receipt of the IRS private letter ruling and / or opinions of counsel or other external tax advisors, the IRS could determine that the distribution and certain related transactions should be treated as taxable transactions for U.S. federal income tax purposes if it determines that any of the facts, assumptions, representations, statements or undertakings that were included in the request for the IRS private letter ruling or on which any opinion was based are false or have been violated.

These entities are now owned 100 % by us or our subsidiaries, and are treated as a consolidated group for federal income tax purposes.

GLPI elected to be taxed as a real estate investment trust («REIT») for United States federal income tax purposes commencing with the 2014 taxable year.

Investors participating in this offering will, by contrast, hold equity in GoDaddy Inc., a Delaware corporation that is a domestic corporation for U.S. federal income tax purposes, in the form of shares of our Class A common stock.

Our post-offering organizational structure will allow the Continuing LLC Owners to retain their equity ownership in Desert Newco, an entity that is classified as a partnership for U.S. federal income tax purposes, in

Furthermore, we will calculate the state and local income tax savings by applying this 5 % rate to the reduction in our taxable income, as determined for U.S. federal income tax purposes, as a result of the tax attributes subject to the TRAs.

In addition, certain events that may or may not be within the control of HP Inc. or Hewlett Packard Enterprise could cause the distribution and certain related transactions to not qualify for tax - free treatment for U.S. federal income tax purposes.

Taxes: Investors should note that even though the dividends are reinvested and that no cash from the dividends was paid to the investor, for federal income tax purposes, the investor will be treated as having received dividend income on the dividend payment date.

The potential tax benefits from investing in MLPs depend on their being treated as partnerships for federal income tax purposes and, if the MLP is deemed to be a corporation, then its income would be subject to federal taxation at the entity level, reducing the amount of cash available for distribution to the fund which could result in a reduction of the fund's value.

For federal income tax purposes, fund distributions of long - term capital gains are generally taxable at reduced long - term capital gain rates.

* HSA contributions, earnings, and distributions used to pay for qualified medical expenses are tax free for federal income tax purposes.

Marriott International said it anticipates the receipt of an IRS private - letter tax ruling in September, confirming that the distribution of shares of Marriott Vacations Worldwide common stock will not result in the recognition, for U.S. federal income tax purposes, of income, gain or loss by Marriott International or Marriott International shareholders, except, in the case of Marriott International shareholders, for cash received in lieu of fractional shares.

NXRT intends to qualify and elect to be taxed as a real estate investment trust, or REIT, for U.S. federal income tax purposes, commencing with its first taxable year of operations as a separate public company.

The change in the current tax law regarding MLPs could result in the MLP being treated as a corporation for federal income tax purposes which would reduce the amount of cash flows distributed by the MLP.

The AMT is a complicated tax calculation that is intended to eliminate the potential for taxpayers to report large financial accounting profits while reporting little taxable income for federal income tax purposes, thus, paying little or no tax.

The Trust is classified as a «grantor trust» for US federal income tax purposes.

• the Trust fails to qualify for treatment, or ceases to be treated, as a grantor trust for US federal income tax purposes, and the Trustee receives notice from the Sponsor that the Sponsor determines that, because of that tax treatment or change in tax treatment, termination of the Trust is advisable;

A Shareholder that is not a US Shareholder as defined above (other than a partnership, or an entity treated as a partnership for US federal income tax purposes) is generally considered a «Non-US Shareholder» for purposes of this discussion.

the Trust fails to qualify for treatment, or ceases to be treated, as a grantor trust for US federal income tax purposes, and the Trustee receives notice from the Sponsor that, because of that tax treatment or change in tax treatment, termination of the Trust is advisable;

For federal income tax purposes, you may deduct as a charitable contribution the price of this ticket less $ 50, our good - faith estimate of the value of the goods or services received.

Contributions to AMERICAblog are not deductible as charitable contributions for federal income tax purposes.

Contributions to the PCCC are not deductible as charitable contributions for federal income tax purposes.

Donations to the American Federation for Children Growth Fund are tax deductible for federal income tax purposes.

A RAM truck typically qualifies as Section 179 property for U.S. Federal Income Tax purposes.

In certain circumstances, the U.S. Internal Revenue Code requires that individual income taxpayers report the refund of excess state or local income tax payments received by the taxpayer as income for federal income tax purposes.

For federal income tax purposes, fund distributions of long - term capital gains are generally taxable at reduced long - term capital gain rates.

The form also shows how much, if any, was withheld from your benefit payments for federal income tax purposes.

For federal income tax purposes, workers» compensation awarded under a workers»...

Any distributions resulting from such gains will be considered ordinary income for federal income tax purposes.

Taxes: Investors should note that even though the dividends are reinvested and that no cash from the dividends was paid to the investor, for federal income tax purposes, the investor will be treated as having received dividend income on the dividend payment date.

Another weird thing: Any penalties you have to pay on your CD can be deducted from your income for US federal income tax purposes.

Withdrawals, including any earnings, are federal tax - free when withdrawn to pay for qualified higher education expenses.1 Contributions are not deductible for federal income tax purposes.

No, contributions to Michigan Education Savings Program (MESP) or any 529 plan are not deductible for federal income tax purposes.