Attributable. A Net Tax Benefit is “Attributable” to a (A) Non-Blocker TRA Holder to the extent that it is derived from any Basis Adjustment, Imputed Interest, Actual Interest Amount or Default Rate Interest that is attributable to an Exchange undertaken by or with respect to such TRA Holder, (B) SC II TRA Holder to the extent that it is derived from any Blocker Attributes, Imputed Interest, Actual Interest Amount or default Rate Interest that is attributable to SC II Blocker or the Reorganization Transactions in respect of SC II Blocker and (C) to SC II PV TRA Holder to the extent that it is derived from any Blocker Attributes, Imputed Interest, Actual Interest or Default Rate Interest that is attributable to SC II ▇▇ ▇▇▇▇▇▇▇ or the Reorganization Transactions in respect of SC II ▇▇ ▇▇▇▇▇▇▇.
Appears in 2 contracts
Sources: Tax Receivable Agreement (Shift4 Payments, Inc.), Tax Receivable Agreement (Shift4 Payments, Inc.)