Final Determination
Final Determination. The final resolution of liability for any Tax for a taxable period, (i) by IRS Form 870 or 870-AD (or any successor form thereto), on the date of the final acceptance by or on behalf of a party thereto, or by a comparable form under the laws of another jurisdiction; except that a Form 870 or 870-AD or comparable form that reserves (whether by its terms or by operation of law) the right of the taxpayer to file a claim for refund and/or the right of taxing authority to assert a further deficiency...
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Found in
Federal-Mogul Holdings Corp contract
Final Determination. With respect to any Income Tax liability, (i) a determination within the meaning of Section 1313(a) of the Code and the Treasury regulations thereunder, (ii) a comparable determination of an Income Tax liability under applicable state, local or non-U.S. Tax law or (iii) any other event that the parties hereto agree is a final resolution of the Income Tax liability at issue
Final Determination. The determination of a court of competent jurisdiction.
Found in
YRC Worldwide Inc. contract
Final Determination. (i) a decision, judgment, decree, or other order by a court of competent jurisdiction, which has become final and unappealable; (ii) a closing agreement or accepted offer in compromise under Code Sections 7121 or 7122, or comparable agreements under the laws of other jurisdictions; (iii) any other final settlement with the IRS or other Taxing Authority; or (iv) the expiration of an applicable statute of limitations.
Found in
Hyatt Hotels Corp contract
Final Determination. The resolution of an issue for the taxable year in question by (A) the expiration of the applicable statute of limitations on assessments for the year, as extended by agreement, (B) a decision, judgment, decree or other order by a court of competent jurisdiction, which has become final and unappealable, or (C) a closing agreement or an accepted offer in compromise under ยง 7121 or 7122 of the Code
Found in
ENTERGY LOUISIANA, LLC contract
Final Determination. With respect to any issue (a) a decision, judgment, decree, or other order by the United States Tax Court or any other court of competent jurisdiction that has become final and unappealable, (b) a closing agreement under Section 7121 of the Code or a comparable provision of any state, local or foreign Tax law that is binding against the Service or any other Tax Authority, (c) any other final settlement with the Service or other Tax Authority, or (d) the expiration of the applicable statute of...
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Final Determination. Shall mean (i) with respect to federal income taxes, (A) a "determination" as defined in Section 1313(a) of the Code, or (B) the date of acceptance by or on behalf of the IRS of Form 870-AD (or any successor form thereto), as a final resolution of Tax liability for any Taxable period, except that a Form 870-AD (or successor form thereto) that reserves the right of the taxpayer to file a claim for Refund or the right of the IRS to assert a further deficiency shall not constitute a Final...
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Found in
MSCI Inc contract
Final Determination. Means a final determination by the Internal Revenue Service or, if such determination is appealed, a final determination by any court of competent jurisdiction.
Final Determination. Shall mean a final "determination" as defined under section 1313 of the Code or under any similar provision for state or local Tax law purposes.
Found in
Activision Blizzard contract
Final Determination. Shall mean the final resolution of any tax matter, including, but not limited to, a closing agreement with the IRS or the relevant state, local or foreign taxing authority, a claim for refund which has been allowed, a deficiency notice with respect to which the period for filing a petition with the United States Tax Court or the relevant state, local or foreign tribunal has expired, or a decision of competent jurisdiction that is not subject to appeal or as to which the time for appeal has...
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Found in
PLY GEM HOLDINGS INC contract
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