IRS Ruling Requests Clause Samples
IRS Ruling Requests. Cable covenants and agrees that, after the Distribution Date, it will not file, and it will cause its Subsidiaries to refrain from filing, any ruling request with the IRS (i) in respect of any part of the Transactions or (ii) that may reasonably be expected to have any effect on the Tax treatment of the Transactions, in each case without the consent of ▇▇▇▇▇▇ (which consent will not be unreasonably withheld or delayed); provided, however, that Cable may request a ruling from the IRS that a transaction described in Section 7.04 will not adversely affect the Intended Tax Treatment.
IRS Ruling Requests. Each Party covenants and agrees that, subsequent to the Closing Date, it will not file, and it will cause its Affiliates to refrain from filing, any ruling request with the IRS in respect of any part of the Transactions or that may reasonably be expected to have any effect on the Tax treatment of the Transactions.
IRS Ruling Requests. Each Party covenants and agrees that, subsequent to the Closing Date, it will not file, and it will cause its Subsidiaries to refrain from filing, any ruling request with the IRS (i) in respect of any part of the Transactions or (ii) that may reasonably be expected to have any effect on the Tax treatment of the Transactions, in each case without the consent of the other Parties (which consent will not be unreasonably withheld or delayed), provided, however, that Berkshire Hathaway may request a ruling from the IRS that a transaction described in Section 9.01(a) will not adversely affect the Berkshire Intended Tax Treatment or the ▇▇▇▇▇▇ Intended Tax Treatment.
