See I Sample Clauses

See I. C. 598.21

See I. R.C. § 197(a), (d)(1)(A) (2012) (explaining that certain intangibles, including goodwill, are ratably amortizable “over the 15-year period beginning with the month in which such intangible was acquired”). TRA payments may extend well beyond fifteen years from the date of the IPO, since pre-IPO owners may sell their partnership interests to the public company several years after the IPO. See, e.g., Vistra Energy Corp. Registration Statement, supra note 1: 902 VANDERBILT LAW REVIEW [Vol. 71:3:889 typically have provisions that accelerate the TRA payment obligations at the election of the public company or when certain events occur, including material breaches by the public company or a merger or acquisition of the public company.57 If the TRA payments are accelerated by one of these events, the public company will be forced to pay for tax benefits under the assumption that the public company is able to fully utilize all of its future tax assets, which in many cases may not be true and would force the public company to pay the pre-IPO owners more than the value the public company actually receives from the tax assets.58