For U. S. federal income tax purposes, (a) from and after the Funding Date the Borrower and the Administrative Agent shall treat the New Term Loans as a “qualified reopening” (within the meaning of Treasury Regulations Section 1.1275-2(k)) of the existing Initial Term Loans, and (b) from and after the Funding Date and/or the Amendment Effective Date solely for purposes of FATCA, the Administrative Agent shall treat the Initial Term Loans (including the New Term Loans) as not qualifying as “grandfathered obligations” within the meaning of Treasury Regulation Section 1.1471-2(b)(2)(i).
Appears in 3 contracts
Samples: Joinder and Amendment Agreement (National Vision Holdings, Inc.), Joinder and Amendment Agreement (National Vision Holdings, Inc.), Joinder and Amendment Agreement (National Vision Holdings, Inc.)
For U. S. federal income tax purposes, (a) from and after the Funding Date the Borrower and the Administrative Agent shall treat the New Term Loans as a “qualified reopening” (within the meaning of Treasury Regulations Section 1.1275-2(k)) of the existing Initial Term Loans, and (b) from and after the Funding Date and/or the Amendment No. 1 Effective Date Date, solely for purposes of FATCA, the Administrative Agent shall treat the Initial Term Loans (including the New Term Loans) as not qualifying as “grandfathered obligations” within the meaning of Treasury Regulation Section 1.1471-2(b)(2)(i).
Appears in 3 contracts
Samples: Joinder Agreement (National Vision Holdings, Inc.), Joinder Agreement (National Vision Holdings, Inc.), Joinder Agreement (National Vision Holdings, Inc.)
