Request for Tax Ruling Clause Samples
Request for Tax Ruling. The parties will request the IRS to issue a private letter ruling holding that New Ashland Inc. is entitled to claim the Specified Liability Deductions. If the IRS issues such a private letter ruling, the Specified Liability Deductions shall be claimed by New Ashland Inc. on the New Ashland Inc. Affiliated Group's consolidated Federal income tax return and not by Marathon or any member of the Marathon Group.
Request for Tax Ruling. EuroBancshares shall promptly prepare and file with the Department of Treasury of Puerto Rico a request for a ruling to the effect that (A) the Merger will be treated as a "tax free reorganization" within the meaning of Section 1112(g)(1)(A) of the Internal Revenue Code of Puerto Rico, and (B) all or substantially all of the NOL's of B&T shall survive the Closing Date and will be available to Eurobank to offset its income and reduce its future tax liabilities to the same extent that such NOL's would otherwise be available to B&T.