IRS Letter Ruling Clause Samples
An IRS Letter Ruling clause outlines the process and requirements for obtaining a private letter ruling from the Internal Revenue Service regarding the tax treatment of a specific transaction or arrangement. Typically, this clause specifies which party is responsible for requesting the ruling, who bears the associated costs, and how the outcome of the ruling will affect the parties’ obligations under the agreement. Its core function is to provide certainty and reduce tax-related risks by ensuring that the parties have authoritative guidance from the IRS before proceeding.
IRS Letter Ruling. The IRS PLR (Decommissioning Funds Transfer), insofar as it relates to CPS, shall have been received with no condition or limitation thereon that is not reasonably acceptable to CPS.
IRS Letter Ruling. TDCC shall have received the Private Letter Ruling, in form and substance reasonably acceptable to TDCC, and such ruling shall continue to be valid and in full force and effect as of the Closing Date.
IRS Letter Ruling. The Company and Parent shall have received the IRS Letter Ruling from the IRS, in form and substance acceptable to Parent and the Company.
IRS Letter Ruling. The IRS PLR (Decommissioning Funds Transfer), insofar as it relates to Texas Genco, shall have been received with no condition or limitation thereon that is not reasonably acceptable to Texas Genco.
IRS Letter Ruling. The IRS ruling set forth in Section 6.8(b) shall have been received with no condition or limitation thereon that is not reasonably acceptable to Purchaser.
IRS Letter Ruling. The IRS Ruling shall have been requested and obtained.
IRS Letter Ruling. A private letter ruling shall be requested and obtained from the IRS that (i) the sale by the ESOP to PA&E for cash and the immediate repayment of the ESOP Debt will not cause the ESOP Debt to fail to be exempt from the prohibited transition rules of ERISA and the Code; and (ii) the allocation of the net proceeds of the sale of unallocated shares to participant accounts will not be treated as annual additions under Code section 415, or alternatively, will not cause annual additions under the ESOP to exceed the limits in Code section 415 (the "IRS Ruling").