WitrynaSample 1. Imputed Underpayments. Notwithstanding anything herein to the contrary, if the IRS seeks to assess an “ imputed underpayment ” (within the meaning of Section 6225 of the Code) against the Company for any Pre- Closing Tax Period, the Buyer will be entitled to cause the Company to make any available election under Section 6226 … Witryna1 lip 2024 · Buyers face the wrong-taxpayer risk for their adjustment-year share of any imputed underpayment relating to pre-acquisition reviewed years unless a push-out …
IMPUTE 意味, Cambridge 英語辞書での定義
Witryna30 lis 2024 · The partnership’s liability for an imputed underpayment is calculated by applying the highest applicable rate for the reviewed year (either the individual or the corporate rate, whichever is higher) to the combined adjustments. This results in an imputed underpayment that likely exceeds the amount of tax that would be due from … WitrynaAlternative To Payment Of Imputed Underpayment By Partnership. I.R.C. § 6226 (a) In General —. If the partnership—. I.R.C. § 6226 (a) (1) —. not later than 45 days after the date of the notice of final partnership adjustment, elects the application of this section with respect to an imputed underpayment, and. I.R.C. § 6226 (a) (2) —. improve w2k19 virtual cpu terminalserver
Allocation of Imputed Underpayment Sample Clauses
WitrynaExcept as otherwise provided in this paragraph (a) (3), the term imputed underpayment means the amount determined in accordance with section 6225 of the Code, 301.6225-1, and, if applicable, 301.6225-2. In the case of an election under section 6226, the term imputed underpayment means the amount determined in accordance with 301.6226 … Witryna1 lip 2016 · The imputed underpayment payable by the partnership is the result of netting all adjustments of income, gain, loss, or deduction for the reviewed year and multiplying the net amount by the "highest rate of tax in effect for the reviewed year under section 1 or 11" (i.e., the higher of the highest individual or corporate rate). 38 Thus, … Witryna8 kwi 2024 · Pass-through partners must determine whether taking the adjustments into account results in an imputed underpayment. Pass-through partners can either pay the imputed underpayment or push out the adjustments to their reviewed year partners. In either case, pass-through partners are required to file a Form 8985, “Pass-Through … lithium and pregnancy risks