Intended Tax Treatment. All parties to this Agreement covenant and agree to treat any purchase of Purchaser Interests and any drawing on a Letter of Credit under this Agreement as debt for all federal income tax purposes. All parties to this Agreement agree not to take any position on any tax return inconsistent with the foregoing.
Appears in 8 contracts
Samples: Receivables Purchase Agreement (Dean Foods Co), Receivables Purchase Agreement (Dean Foods Co), Receivables Purchase Agreement (Dean Foods Co)
Intended Tax Treatment. All parties to this Agreement covenant and agree to treat any purchase of Purchaser Interests Purchase and any drawing on a Letter of Credit under this Agreement as debt for all federal income tax purposespurposes (the “Intended Tax Treatment”). All parties to this Agreement agree not to take any position on any tax return inconsistent with the foregoingIntended Tax Treatment.
Appears in 4 contracts
Samples: Receivables Purchase Agreement (Owens Corning), Receivables Purchase Agreement (Owens Corning), Receivables Purchase Agreement (Owens Corning)
Intended Tax Treatment. All parties to this Agreement covenant and agree to treat any purchase of Purchaser Interests and any drawing on a Letter of Credit Purchase under this Agreement as debt for all federal income tax purposespurposes (the “Intended Tax Treatment”). All parties to this Agreement agree not to take any position on any tax return inconsistent with the foregoingIntended Tax Treatment.
Appears in 3 contracts
Samples: Receivables Purchase Agreement (Cloud Peak Energy Inc.), Receivables Purchase Agreement (Cloud Peak Energy Inc.), Receivables Purchase Agreement (Cloud Peak Energy Resources LLC)
Intended Tax Treatment. All parties to this Agreement covenant and agree to treat any purchase of Purchaser Interests and any drawing on a any Letter of Credit under this Agreement as debt of the Borrower to the Issuing Lender for all federal income tax purposesTax purposes (the “Intended Tax Treatment”). All parties to this Agreement agree not to take any position on any tax Tax return inconsistent with the foregoingIntended Tax Treatment.
Appears in 1 contract
Samples: Reimbursement Agreement (Hamilton Insurance Group, Ltd.)
Intended Tax Treatment. All parties to this Agreement covenant and agree to treat any purchase of Purchaser Interests Purchase and any drawing on a Letter of Credit under this Agreement as debt for all federal income tax purposespurposes (the “Intended Tax Treatment”). All parties to this Agreement agree not to take any position on any tax return inconsistent with the foregoing.Intended Tax Treatment
Appears in 1 contract
Intended Tax Treatment. All parties to this Agreement covenant and agree to treat any purchase of Purchaser Interests Advance and any drawing on a Letter of Credit under this Agreement as debt for all U.S. federal income tax purposes. All parties purposes and to this Agreement agree not to take any position on any tax return inconsistent with the foregoing, except as otherwise required pursuant to a “determination” within the meaning of Section 1313(a) of the Code (or any comparable provision of any state, local or foreign law).
Appears in 1 contract
Samples: Credit and Security Agreement (Quest Diagnostics Inc)
