Qualified Subchapter S Subsidiary Election effective as of the Contribution Date, to treat DAS as a “qualified subchapter S subsidiary” within the meaning of Section 1361(b)(3)(B) of the Code (the “Q-Sub Election”, and together with the Contribution, the “F-Reorganization”).
Qualified Subchapter S Subsidiary Election. The Shareholders shall have received documentation from the IRS indicating that the Subsidiary made a valid election to be treated as a qualified subchapter S subsidiary within the meaning of Section 1361(b)(3)(B) of the Code as of October 17, 1997.
Qualified Subchapter S Subsidiary Election. ADC shall have delivered to Parent a copy of the election made with respect to PTFS to treat PTFS as a "qualified subchapter S subsidiary" (within the meaning of Section 1361(b)(3)(B)) of ADC and documentation reasonably acceptable to Parent evidencing that such election was timely filed.
Qualified Subchapter S Subsidiary Election. NCI and the Shareholder agree that they shall cause NCI-VA to make and shall consent to the making of, an election by NCI to treat NCI-VA as a qualified subchapter S subsidiary under Section 1361(b)(3) of the Code, effective as of the Closing Date.
Qualified Subchapter S Subsidiary Election. ¸ effective as of the date of the Contribution (the “QSub Election”).
