IRS Ruling. The Company shall have obtained a favorable written ruling from the United States Internal Revenue Service confirming the qualification of each of the GGO Share Distribution and the prerequisite internal spin-offs each as a “tax free spin-off” under the Code.
Appears in 11 contracts
Samples: Stock Purchase Agreement (Pershing Square Capital Management, L.P.), Stock Purchase Agreement (General Growth Properties, Inc.), Stock Purchase Agreement (General Growth Properties, Inc.)
IRS Ruling. The Company shall have obtained a favorable written ruling from the United States Internal Revenue Service confirming the qualification of each of the GGO Share Distribution and the prerequisite internal spin-offs each as a “tax free spin-off” under the Code.
Appears in 7 contracts
Samples: Investment Agreement, Cornerstone Investment Agreement (General Growth Properties, Inc.), Stock Purchase Agreement (Pershing Square Capital Management, L.P.)
