83(b) Election. The Executive will make an election pursuant to Section 83(b) of the U.S. Internal Revenue Code in respect of the Incentive Securities within 30 days following the issuance thereof to the Executive. The Incentive Securities are intended to constitute, and shall be treated for all purposes, as “profits interests” within the meaning of Revenue Procedures 93-27 and 2001-43 and any other official guidance promulgated thereafter.
Appears in 5 contracts
Samples: Employment Agreement (Styron Canada ULC), Executive Subscription and Securityholder’s Agreement (Styron Canada ULC), Executive Subscription and Securityholder’s Agreement (Styron Canada ULC)