IRS Ruling. The parties acknowledge that CSI currently plans to seek ---------- a private letter ruling from the Internal Revenue Service to the effect that (i) Section 355 of the Code will apply to a Distribution of Newco stock by CSI to CSI's stockholders; and (ii) no gain or loss will be recognized by (and no amounts will be included in the income of) the stockholders of CSI upon their receipt of Newco stock pursuant to the Distribution.
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Samples: Transformation Agreement (Cabletron Systems Inc), Transformation Agreement (Aprisma Management Technologies Inc), Transformation Agreement (Cabletron Systems Inc)
IRS Ruling. The parties acknowledge that CSI currently plans to seek ---------- a private letter ruling from the Internal Revenue Service to the effect that (i) Section 355 of the Code will apply to a Distribution of Newco stock by CSI to CSI's stockholders; and (ii) no gain or loss will be recognized by (and no amounts will be included in the income of) the stockholders of CSI upon their receipt of Newco stock pursuant to the Distribution.
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