Section 336(e) Election has the meaning set forth in Section 7.06.
Section 336(e) Election has the meaning set forth in Section 3.4.
Section 336(e) Election shall have the meaning set forth in Section 4(d).
Examples of Section 336(e) Election in a sentence
For the avoidance of doubt, such agreement is intended to constitute a written, binding agreement to make the Protective Section 336(e) Election within the meaning of Treasury Regulations § 1.336-2(h)(1)(i).
Each Party agrees not to take any position (and to cause each of its Affiliates not to take any position) that is inconsistent with the Protective Section 336(e) Election, including the Section 336(e) Allocation Statement, on any Tax Return, in connection with any Tax Contest or for any other Tax purposes (in each case, excluding any position taken for financial accounting purposes), except as required by a Final Determination.
More Definitions of Section 336(e) Election
Section 336(e) Election shall have the meaning set forth in Section 7.06 of this Agreement.
Section 336(e) Election has the meaning set forth in the Tax Matters Agreement.
Section 336(e) Election has the meaning set forth in Section 7.06. “Section 7.02(e) Acquisition Transaction” means any transaction or series of transactions that is not a Proposed Acquisition Transaction but would be a Proposed Acquisition Transaction if the percentage reflected in the definition of Proposed Acquisition Transaction were 25% instead of 40%.
Section 336(e) Election shall have the meaning assigned to it in Section 15.01.
Section 336(e) Election has the meaning set forth in Section 10(a). “Section 9(b)(iv)(F) Acquisition Transaction” has the meaning set forth in Section 9(b)(iv)(F).
Section 336(e) Election means an election described in Section 336(e) of the Code with respect to the RHW Spinout. The term “Section 336(e) Election” shall include any corresponding election under state or local Law pursuant to which a separate election is permissible with respect to the RHW Spinout.