Sentences with phrase «purpose entities as»

Successfully represented mortgage lender in opposing debtors» plan to treat mortgage loans to separate special purpose entities as if all loans had been made to only a single entity.

Not exact matches

«Washington law treats trade associations contributing their own funds as single entities for disclosure purposes,» it says.
By selling altcoins and tokens for the purpose of financing or utilizing projects, companies that would be recognized as too risky or too small by traditional investment entities have a means to raise large amounts of seed capital.
Electronic firearm tracking technology is defined as «a platform, system or device or a group of systems or devices that uses a shared ledger, distributed ledger or block chain technology or any other similar form of technology or electronic database for the purpose of storing information in a decentralized or centralized way, that is not owned or controlled by any single person or entity and that is used to locate or control the use of a firearm.»
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.
As at the end of March 2013, international investment position (IIP) data indicated that Australian entities overall had a net foreign currency asset position equivalent to 27 per cent of GDP before taking into account the use of derivatives for hedging purposes (ABS 2013a).
Single - purpose entities are normally incorporated as limited companies or limited partnerships.
Corporate personhood is easily ridiculed on late - night television, but as Eric Posner pointed out in Slate, the law often «treats various nonhuman, nonsentient entities as «persons» for certain legal 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.
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.
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.
These entities are now owned 100 % by us or our subsidiaries, and are treated as a consolidated group for federal income tax purposes.
The Transaction was treated as a reverse acquisition of Croe, and the Company is treated as the acquirer, for financial accounting and reporting purposes, while Croe is treated as the acquired entity.
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
Our effective tax rate differs from statutory rates primarily due to our pass - through entity structure for U.S. income tax purposes, while being treated as taxable in certain states and various foreign countries as well as for certain subsidiaries.
For general purposes, though, it includes direct owners who own at least 25 % of the company; the owners of any entities that own a portion of the company so long as the individuals each have at least a 25 % stake in the company); and so on.
(2) Unlike U.S. municipalities such as Detroit, Puerto Rico entities aren't considered debtors for purposes of Chapter 9 of the U.S. Bankruptcy Code.
This structure is more commonly used in the social sector and so long as the main purpose of the entity is not - for - profit, it can accumulate excess profits from year to year.
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 the purposes of The Long View, CCBE defined family firms as public issuers with at least 30 % of votes controlled by a family entity.
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.
Just as every entity requires an explanation of its being in terms of an efficient cause of being (the second argument), so also it requires an explanation in terms of final cause or purpose.
For purposes of illustration, let us have a simple example: A and B are actual entities, and B prehends A. And so there is the nexus — call it the A-B nexus — that is constituted by B's prehension of A. 6 The phrase «prehensions of each other» in the category suggests that, in order to have a nexus, A must also prehend B. However, I think that Whitehead used that phrase loosely, and so its meaning can also be expressed as «prehensions of one another.»
Zionism's messianic character is evident in its attempt to end the role of the Jews as a ghost - people, to keep Jewry from retaining the status of an unclassifiable entity, and to reactivate the spiritual purpose to which Jews have traditionally considered themselves covenanted (NZ 177).
Although we would rather talk of the coherent unity of the causal complex, because, even when the development of a complex entity can be traced through contributary causes, the interlocking patterning of those causes through time and space and the higher meaningful unit of organisation which they produce still reveals order and purpose in the system which points to Transcendent Mind as First and Final creative cause.
7 Since for our purposes here the question is not of crucial moment, we shall accept in general, as we have in the preceding essays, the now conventional view of the entity and relative dating of the documents in the order J, E, D, H, P. recognizing with Bentzen, op.
In previous chapters the case has been made for a crucial role for purpose as a causal agency in human life, in the rest of the living world and in all individual entities to the farthest reaches of the universe.
At first one tried to understand these new entities as particles of matter, and for some purposes this imagery worked well.
These bitterly suppressed people in their ragged procession, remembering now the word of Moses conveying the Word of Another, in overwhelming realization that only this Word could effect so glorious and impossible an outcome; this company of the lost, the enslaved, the dying, now found and freed and given life by God; this weak, diffuse body of humanity suddenly made almost terrifyingly aware of its unity and entity as created out of God's unfathomable purpose - these people in this company, in this body, all break forth into a spontaneous hymn of praise, more shout than song, more chant than anthem, more cry of ecstasy than conscious composition:
(vi) SPONSOR ENTITIES MAKE NO WARRANTIES, REPRESENTATIONS OR GUARANTEES, EXPRESS OR IMPLIED, IN FACT OR IN LAW, AS REGARDS THIS PROMOTION OR THE MERCHANTABILITY, QUALITY OR FITNESS FOR A PARTICULAR PURPOSE REGARDING ANY PRIZE OR ANY COMPONENT OF ANY PRIZE.
For the purposes of this section, a State sector agency means any part of the State services as defined in section 2 of the State Sector Act 1988, any Crown entity within the meaning of section 7 of the Crown Entities Act 2004, and any State enterprise within the meaning of the State - Owned Enterprises Act 1986.
Susan Lerner, the executive director of Common Cause, said she would like to see an end to the practice of treating LLCs as independent entities for purposes of campaign finance laws, a ban or else «absolute transparency» for legislators» side jobs and an end to pots of discretionary funding that lawmakers can direct.
Those groups in competition are defined as entities that serve the same purpose of the District at the same age level, i.e., charter schools.»
The Utah State Board of Education approved the appointment of Utah State Office of Education Property Tax and Minimum School Program Specialist Cathy Dudley as the Board's representative for redevelopment agency and taxing entity committee purposes.
While their primary purpose has been to support Eva Moskowitz and the other New York Charter School operators, Families for Excellent Schools arrived in Connecticut from New York last year and registered both Families for Excellent Schools AND Families for Excellent Schools Advocacy as lobbying entities with Connecticut's Office of State Ethics.
Independent chartering boards (ICBs), also known as charter schools «commissions» or «institutes»; these entities are statewide bodies whose sole purpose is authorizing charter schools.
-- For purposes of section 202 of this Act and section 504 of the Rehabilitation Act of 1973 (29 U.S.C. 794), it shall be considered discrimination for a public entity that provides designated public transportation to fail, in accordance with the provisions of this subsection, to make key stations (as determined under criteria established by the Secretary by regulation) in rapid rail and light rail systems readily accessible to and usable by individuals with disabilities, including individuals who use wheelchairs.
-- For purposes of paragraph (2)(C), in determining whether a first or subsequent violation has occurred, a determination in a single action, by judgment or settlement, that the covered entity has engaged in more than one discriminatory act shall be counted as a single violation.
The purpose of the Executive Order is to ensure that regulatory agencies and the SBA Office of Advocacy work closely together as early as possible in the regulatory drafting process to address disproportionate impacts on small entities and appropriately reduce their regulatory burden.
The Secretary shall accept, for the purpose of making a finding with regard to adequate collateral for a public entity, the net present value on a future stream of State or local subsidy income or a dedicated revenue as collateral offered to secure a loan.
The narrators are a member of a doomsday cult who releases poison gas in a subway in Tokyo, and details his retreat to Okinawa and a small nearby island, Kume - jima; a jazz aficionado who works as a sales clerk in a Tokyo music store; a lawyer in a financial institution in Hong Kong who has been moving large sums of money from a certain account; a woman who owns a Tea Shack on China's Holy Mountain and speaks to a tree; a non-corporeal sentient entity which is searching for who or what it is; a gallery attendant in Petersburg who is involved in an art theft scam; a ghostwriter / drummer living in London who saves a woman from being run over by a taxi; an Irish nuclear physicist who quits her job when she finds her research is being used for military purposes; and a late night radio talkback DJ who finds himself fielding calls from an intriguing caller referring to himself as the zookeeper.
Colborne Communications — not especially widely known to many in the US market — is positioned as a provider of broadening menu of services not only for authors but also for publishers and for corporate and government entities that are becoming publishers for various purposes of public and internal messaging.
Publishers are not in business to preserve content for historical purposes, and as a commercial entity, I'd argue a potential conflict of interest.
An independent director may be appointed as well in order for the special purpose entity to maintain neutrality.
As shown above, Plaza Building Holdings LLC is the special purpose entity which secures a 100 % interest against the borrower, Plaza Building LLC.
Certain non-profit organisations, with independent branches (units), have the option of treating their units as if they were separate entities for GST purposes and not part of the main organisation.
This profitable trade of an asset wasn't through a broker where accounts may be opened as an individual's or under the name of a business entity, but the accounting is segregated enough to be associated with the LLC purpose
If we assume that the insured is a sole proprietor or trading as one of certain types of pass - through entities and there were a total fire loss including the computer, the computer may not be covered because it's used primarily for business purposes.
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