No Rulings. Neither Seller with respect to the Project Company or with respect to its assets or operations nor the Project Company has received any ruling of a Taxing Authority relating to Taxes or has withdrawn a ruling request before the ruling was issued.
No Rulings. To Seller’s Knowledge, no Sunlight Company or any Affiliate thereof (a) has received any private letter ruling or closing agreement from the IRS (or any comparable ruling or agreement from any other Taxing Authority) with respect to any Sunlight Company or (b) has any requests for such a ruling or agreement pending.
No Rulings. Target has not received a tax ruling or entered into an agreement with a taxing authority, which ruling or agreement has or could have an affect on the Taxes of Target payable on or after the Effective Date.