Special Tax Treatment Sample Clauses

Special Tax Treatment. Capital gains treatment and 10-year forward income averaging authorized by IRC Sec. 402 do not apply to IRA distributions.
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Special Tax Treatment. Capital gains treatment and 10-year income averaging authorized by IRC Sec. 402 do not apply to Xxxx XXX distributions.
Sample 1Sample 2Sample 3See All (126)
Special Tax Treatment. Capital gains treatment and 10-year forward income averaging authorized by Code Section 402 do not apply to XXX distributions.
Sample 1Sample 2See All (7)
Special Tax Treatment. Capital gains treatment and the favorable five or ten-year forward averaging tax under Code Section 402 do not apply to HSA distributions.
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Special Tax Treatment. Upon the contribution of all of the Contributed Interests to the Partnership as described in the Recitals to this Agreement, Eclipse I will be treated for federal income tax purposes (and state and local income tax purposes, as applicable) as merging with and into the Partnership in an assets-over form (as that term is defined in Treasury Regulation Section 1.708-1(c)(3)). In accordance with the provisions of Treasury Regulation Section 1.708-1(c)(1), the Partnership will be treated as a continuation of Eclipse I for federal income tax purposes (and state and local income tax purposes, as applicable) (including retaining the employer identification number of Eclipse I). The tax year of the Partnership, as the continuation of Eclipse I, shall not terminate as a result of such transactions.
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Special Tax Treatment. Capital gains treatment and 10-year forward income averaging authorized by Code
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Special Tax Treatment. If your eligible rollover distribution is not rolled over, it will be taxed in the year you receive it. However, if it qualifies as a "lump sum distribution," it may be eligible for special tax treatment. A lump sum distribution is a payment, within one year, of your entire balance under the Plan (and certain other similar plans of the employer) that is payable to you because you have reached age 59-1/2 or have separated from service with your employer (or, in the case of a self-employed individual, because you have reached age 59-1/2 or have become disabled). For a payment to qualify as a lump sum distribution, you must have been a participant in the Plan for at least 5 years. The special tax treatment for lump sum distributions is described below.
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Related to Special Tax Treatment

  • Intended Tax Treatment (a) For U.S. federal income tax purposes (and for purposes of any applicable state or local Tax that follows the U.S. federal income tax treatment), the parties hereto intend that (i) the First Merger and the Second Merger, taken together, will constitute an integrated transaction that qualifies as a “reorganization” within the meaning of Section 368(a) of the Code, and (ii) this Agreement will constitute a “plan of reorganization” for the purposes of Section 368 of the Code and Treasury Regulations Sections 1.368-2(g) and 1.368-3(a) (clauses (i) and (ii) collectively, the “Intended Tax Treatment”). (b) So long as the conditions set forth on Exhibit D are satisfied, then (i) each party hereto will agree to prepare and file all Tax Returns consistent with the position that the Mergers qualify for the Intended Tax Treatment, and (ii) no party shall take any position on any Tax Return or during the course of any audit, litigation or other proceeding with respect to Taxes that is inconsistent with the Intended Tax Treatment, except, in each case, as otherwise required by a final determination by a taxing authority or a change in applicable Law after the date of this Agreement. (c) The parties shall cooperate with each other and their respective counsel and use their reasonable best efforts to cause the conditions set forth on Exhibit D to be satisfied. Neither the Company nor Parent shall, or shall cause or permit any of their respective Subsidiaries to, take or omit to take any reasonable action not required or contemplated by this Agreement, as a result of which the Mergers would reasonably be expected to fail to qualify for the Intended Tax Treatment. (d) Parent shall reasonably promptly notify the Company, and the Company shall reasonably promptly notify the Parent, in each case if such party becomes aware of any non-public fact or circumstance that would reasonably be likely to prevent or impede the Mergers from qualifying for the Intended Tax Treatment.

  • Tax Treatment If any interest in any Loan Document is transferred to any Transferee which is organized under the laws of any jurisdiction other than the United States or any State thereof, the transferor Lender shall cause such Transferee, concurrently with the effectiveness of such transfer, to comply with the provisions of Section 3.5(iv).

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