Determination Letter Request. UpstreamCo shall submit an application to the IRS as soon as practicable after the Operational Separation Date (but no later than the last day of the applicable remedial amendment period as defined in applicable Code provisions) requesting a determination letter regarding the qualified status of the UpstreamCo Savings Plans under Sections 401(a) and 401(k) of the Code and the tax-exempt status of their related trust under Section 501(a) of the Code and shall make any amendments reasonably requested by the IRS to receive such a favorable determination letter.
Appears in 4 contracts
Samples: Employee Matters Agreement, Employee Matters Agreement (Alcoa Corp), Employee Matters Agreement (Arconic Inc.)
Determination Letter Request. UpstreamCo shall submit an application to the IRS as soon as practicable after the Operational Separation Date (but no later than the last day of the applicable remedial amendment period as defined in applicable Code provisions) requesting a determination letter regarding the qualified status of the UpstreamCo Savings Pension Plans under Sections Section 401(a) and 401(k) of the Code and the tax-exempt status of their related trust the UpstreamCo Pension Trust under Section 501(a) of the Code as of the Operational Separation Date and shall make any amendments reasonably requested by the IRS to receive such a favorable determination letter.
Appears in 4 contracts
Samples: Employee Matters Agreement, Employee Matters Agreement (Arconic Inc.), Employee Matters Agreement (Alcoa Corp)
