Grantor Trusts. If all or a portion of an ESBT is treated as owned by a person under subpart E, part I, sub- chapter J, chapter 1 of the Internal Revenue Code, such owner is a poten- tial current beneficiary in addition to persons described in paragraph (m)(4)(i) of this section.
Grantor Trusts. Monsanto and PNU shall each take all steps (if any) that are necessary or appropriate to amend any grantor trusts to which Monsanto or any of its Subsidiaries, or PNU or any of its Subsidiaries, as applicable, is a party so that no contributions to such trusts are required to be made as a result of or in connection with the consummation of the transactions contemplated hereby.
Grantor Trusts. On or prior to the Effective Time, Xxxxxxxx 66 shall, or shall cause another Xxxxxxxx 66 Entity to, adopt a grantor trust in a form that is substantially comparable to the COP Grantor Trust as in effect immediately prior to the Effective Time. In connection with the assumption of the Liabilities under the COP SERP and the COP Deferred Compensation Plans in respect of Xxxxxxxx 66 Group Employees, COP shall (or shall cause a COP Entity to), as soon as reasonably practicable after the Effective Time in respect of the Xxxxxxxx 66 SERP and Xxxxxxxx 66 Deferred Compensation Plans, transfer Assets in an amount equal to the funded percentage of such Liabilities (as determined by the COP Actuary) as of the Effective Time to such grantor trust as of the Effective Time.
Grantor Trusts. Prior to the Deferred Compensation Transfer Date, Civeo shall, or shall cause a member of the Civeo Group to, adopt a grantor trust in a form that is substantially comparable to the OS Grantor Trust as in effect immediately prior to the Effective Time (the “Civeo Grantor Trust”). Subject to obtaining any required consents, in connection with the assumption of the Liabilities under the OS Deferred Compensation Plan in respect of Civeo Deferred Compensation Beneficiaries, Oil States shall (or shall cause a member of the OS Group to), on the Deferred Compensation Transfer Date, transfer Assets to the Civeo Grantor Trust in an amount equal to the funded percentage of such Liabilities (as reasonably determined by Oil States) as of the Effective Time less any Assets used to fund benefits payable to Civeo Deferred Compensation Beneficiaries during the period commencing on the Distribution Date and ending on the Deferred Compensation Transfer Date. Oil States and Civeo agree to cooperate in good faith to obtain any consents required to effectuate the transfer of Assets set forth in this Section 7.4.
Grantor Trusts. On or prior to the Effective Time, New SAIC shall, or shall cause another New SAIC Entity to, adopt one or more grantor trusts in a form or forms that are substantially comparable to the Leidos Grantor Trusts as in effect immediately prior to the Effective Time. In connection with the assumption of the Liabilities under the Leidos Excess Deferral Plan and the Leidos Deferred Compensation Plans in respect of New SAIC Group Employees and New SAIC Directors, Leidos shall (or shall cause a Leidos Entity to), as soon as reasonably practicable after the Effective Time in respect of the New SAIC Excess Deferral Plan and New SAIC Deferred Compensation Plans, transfer Assets in an amount equal to the funded percentage of such Liabilities as of the Effective Time to such grantor trust.
Grantor Trusts. Certain Transferred Employees and AbbVie LTD Participants who are participating in the Abbott SERP, the Abbott KSP, the Abbott Performance Incentive Plan, and/or the Abbott Management Incentive Plan, as applicable, have established grantor trusts in connection with such plans. Prior to the Distribution Date, the Parties shall use commercially reasonable efforts to cause each grantor trust under such plans to be amended to provide that (a) AbbVie is the administrator of such trust and (b) distribution of amounts under such trusts is made by reference to termination of employment with the AbbVie Group and not termination of employment with the Abbott Group.
Grantor Trusts. On or prior to the Effective Time, CRC shall, or shall cause a member of the CRC Group to, adopt a grantor trust (the “CRC Grantor Trust”). In connection with the assumption of the Liabilities under the OPC Deferred Compensation Plans in respect of CRC Deferred Compensation Beneficiaries, OPC shall (or shall cause a member of the OPC Group to), as soon as reasonably practicable after the Effective Time), transfer Assets in an amount equal to amounts funded in the OPC [name of grantor trust] with respect to CRC Deferred Compensation Beneficiaries (as determined by OPC) as of the Effective Time to the CRC Grantor Trust. The form of the Asset transfers described in this Section 8.5 shall be in the sole discretion of OPC.]
Grantor Trusts. A payment made under a grandfathered obligation in- cludes a payment made to a grantor trust with respect to such obligation, including a payment made with respect to the trust’s disposition of such obli- gation. A payment made under a grandfathered obligation also includes income from such obligation that is in- cludible in the gross income of a person that is treated as an owner of the trust and the gross proceeds from the dis- position of such obligation to the ex- tent such owner is treated as owning the portion of the trust that consists of the obligation.
Grantor Trusts. LBI and USAuto shall each take all steps (if any) that are necessary or appropriate to amend any grantor trusts to which LBI or any of its Subsidiaries, or USAuto or any of its Subsidiaries, as applicable, is a party so that no contributions to such trusts are required to be made as a result of or in connection with the consummation of the transactions contemplated hereby.
Grantor Trusts. During the period of the duration of the -------------- Joint Settlement Agreement, no member of the Ampex Group or the Sherborne Group (or AFC) shall transfer any amounts to a trust the assets of which are not available to creditors in the absence of the commencement of a bankruptcy proceeding.
