Tax Treatment. [One or more elections will be made to treat the assets of the Trust Fund as a REMIC.] [The Trust Fund will be treated as a "grantor trust" for federal income tax purposes.]
Tax Treatment shall have the meaning set forth in Section 24.05.
Tax Treatment has the meaning set forth in Section 3.12.
Examples of Tax Treatment in a sentence
The Parties agree to the Tax treatment of the Transaction (including, for the avoidance of doubt, any Deferred Consideration and the Closing Date Equity Consideration) specified in Section 5(a) of the Joinder Agreement and further agree to refrain from taking any action that would reasonably be expected to prevent or impede the Transaction from qualifying for such Tax treatment.
The parties shall cooperate with each other and their respective counsel to document and support the Tax treatment of the Merger as a “reorganization” within the meaning of Section 368(a) of the Code, including providing factual support letters.
More Definitions of Tax Treatment
Tax Treatment means U.S. federal income tax treatment, and “tax structure” is limited to any facts relevant to the U.S. federal income tax treatment of the potential investment but shall not include information regarding the identity of the parties thereto.
Tax Treatment has the meaning set forth in Section 5.1.
Tax Treatment means the purported or claimed Federal income tax treatment of the transaction, and “tax structure” means any fact that may be relevant to understanding the purported or claimed Federal income tax treatment of the transaction. This paragraph is intended to reflect the understanding of each Credit Agreement Party, each Agent and each Lender that the Transaction is not a “confidential transaction” as that phrase is used in Treasury Regulation § 1.6011-4(b)(3)(i), and shall be interpreted in a manner consistent therewith. Nothing herein is intended to imply that any of each Credit Agreement Party, each Agent and each Lender made or provided a statement, oral or written, to, or for the benefit of, any of each other as to any potential tax consequences that are related to, or may result from, the Transaction.
Tax Treatment is the purported or claimed United States federal income tax treatment of a transaction and “tax structure” is limited to any fact that may be relevant to understanding the purported or claimed United States federal income tax treatment of a transaction. For this purpose, the names of the Partnership, the Partners, their affiliates, the names of their partners, members or equity holders and the representatives, agents and tax advisors of any of the foregoing are not items of tax structure. Section 9.9
Tax Treatment shall have the meaning set forth in Section 7.2(c) hereof.
Tax Treatment means the purported or claimed U.S. federal income tax treatment of the Transaction, and "tax structure" means any fact that may be relevant to understanding the purported or claimed U.S. federal income tax treatment of the Transaction. This paragraph is intended to reflect the understanding of the parties hereto that the Transaction has not been offered under "conditions of confidentiality" as that phrase is used in Treasury Regulation Sections 1.6011-4(b)(3)(i) and 30 1.6111-2(c)(1), and shall be interpreted in a manner consistent therewith.
Tax Treatment and "tax structure" have the meanings specified in Treasury Regulation section 1.6011-4(c).