Controlled 1 definition

Controlled 1 means xpedx Holdings S.A.R.
Controlled 1 has the meaning set forth in the IRS Ruling Request.

Examples of Controlled 1 in a sentence

  • Each of UWWH, IP and Spinco represents and warrants, as of the date hereof and as of the Effective Time, that it knows of no fact (after due inquiry) that would prevent the Tax treatment of the Controlled 1 Contribution, the First Internal Distribution, the Second Internal Distribution, the Third Internal Distribution, the Spinco Contribution, the Distribution or any other Covered Transaction from being consistent with the Tax-Free Status of the Transactions.

  • Date: March 25, 1999 Distributing= Controlled 1 = Controlled 2 = Business A = Business B = Business C = Option Plan A =Option Plan B=D Dear= This is in response to your letters of October 12, and November 25, 1998, requesting rulings concerning the application of sections 83 and 162 of the Internal Revenue Code to the transaction described below.

  • On Date 3, Distributing formed Controlled 1 Sub and Controlled 2, both State AA corporations, and filed the election under Section 1361(b)(3) to treat both Controlled 1 Sub and Controlled 2 as qualified subchapter S subsidiaries (“QSubs”).

  • Representation The following representation is made in connection with this supplemental ruling letter: Distributing and Controlled 1 do not expect that Distributing will be required to make any payments under the Distributing Guaranty following the date of the External Spin-off.

  • Controlled 1 will not issue stock or securities to a person other than Distributing in anticipation of the External Distribution, with the possible exception of the issuances of debt instruments by Controlled 1 to third- party investors in the capital markets pursuant to the Debt Issuances, which instruments may constitute Controlled 1 Securities.

  • The Business A Assets will include the Business A assets of Sub 1 received from Sub 1 LLC in step (iii) above (c of Sub 1’s total assets), the stock of Controlled 1, and ownership interests in other domestic and foreign entities engaged in aspects of Business A.

  • Sub 1 and Sub 2, wholly owned subsidiaries of Controlled 1, are engaged in Business L and Business M, and Business N, respectively.

  • Controlled 1 will be formed by Distributing as a State AA corporation to facilitate the Proposed Transaction (defined below).

  • On the Effective Date, Controlled 1 agrees to assume and become responsible for liabilities, contracts and obligations relating to Distributing's fossil generation assets and business, whether accrued, contingent, or otherwise.

  • The fair market value of the assets of Controlled 1 will exceed the amount of its liabilities immediately after the exchange.

Related to Controlled 1

  • Controlled Company means a company having not more than fifty members and controlled, in the manner described by section 139, by not more than five persons;

  • Section 385 Controlled Partnership has the meaning set forth in Treasury Regulation Section 1.385-1(c)(1) for a “controlled partnership”.

  • Controlled Entities means those entities (including special purpose entities) over which another party has the power to govern, directly or indirectly, decision making in relation to financial and operating policies, so as to require that entity to conform with such controlling party’s objectives;

  • Controlled Entity means (a) any of the Subsidiaries of the Company and any of their or the Company’s respective Controlled Affiliates and (b) if the Company has a parent company, such parent company and its Controlled Affiliates.

  • Commonly Controlled Entity an entity, whether or not incorporated, that is under common control with the Borrower within the meaning of Section 4001 of ERISA or is part of a group that includes the Borrower and that is treated as a single employer under Section 414 of the Code.

  • Controlled Investment Affiliate means, as to any Person, any other Person, other than any Sponsor, which directly or indirectly is in control of, is controlled by, or is under common control with such Person and is organized by such Person (or any Person controlling such Person) primarily for making direct or indirect equity or debt investments in the Borrower and/or other companies.

  • Controlled have meanings correlative to the foregoing.

  • Controlled Shares in reference to any person means all shares of the Company directly, indirectly or constructively owned by such person as determined pursuant to Section 958 of the Code.

  • Controlled Group Liability means any and all liabilities (i) under Title IV of ERISA, (ii) under Section 302 of ERISA, (iii) under Sections 412 and 4971 of the Code, (iv) as a result of a failure to comply with the continuation coverage requirements of Section 601 et seq. of ERISA and Section 4980B of the Code, and (v) under corresponding or similar provisions of foreign laws or regulations.

  • Controlled substance means a controlled substance in schedules I through V of Section 202 of the Controlled Substances Act (2l U.S.C. 8l2) and as further defined in regulation at 2l CFR l308.ll-l308.l5.

  • controlled airspace means an airspace of defined dimensions within which air traffic control service is provided in accordance with the airspace classification;

  • controlled flight means any flight which is subject to an air traffic control clearance;

  • Controlled Subsidiary means any Subsidiary of the Company, 50% or more of the outstanding equity interests of which are owned by the Company and its direct or indirect Subsidiaries and of which the Company possesses, directly or indirectly, the power to direct or cause the direction of the management or policies, whether through the ownership of voting equity interests, by agreement or otherwise.

  • Controlled dangerous substance means a drug, substance, or

  • Controlled Group means all members of a controlled group of corporations or other business entities and all trades or businesses (whether or not incorporated) under common control which, together with the Borrower or any of its Subsidiaries, are treated as a single employer under Section 414 of the Code.

  • Controlled Affiliates means, with respect to a specified Person, another Person that directly, or indirectly through one or more intermediaries, has Majority Control of or is Majority Controlled by or is under common Majority Control with the Person specified.

  • Controlled Foreign Corporation means “controlled foreign corporation” as defined in the Tax Code.

  • Controlled substances means those substances identified in 49 CFR 40.85. “CCF” means the Federal Drug Testing Custody and Control Form.

  • IESO-Controlled Grid means the transmission systems with respect to which, pursuant to agreements, the IESO has authority to direct operation;

  • CAISO Controlled Grid has the meaning set forth in the CAISO Tariff.

  • Controlled Deposit Account means each deposit account (including all funds on deposit therein) that is the subject of an effective Control Agreement and that is maintained by any Loan Party with a financial institution approved by the Administrative Agent.

  • Controlled Group Member means each trade or business (whether or not incorporated) which together with the Borrower is treated as a single employer under Sections 4001(a)(14) or 4001(b)(1) of ERISA or Sections 414(b), (c), (m) or (o) of the Code.

  • Controlled Deposit Amount means, with respect to any Transfer Date, the sum of (a) the Controlled Accumulation Amount for such Transfer Date and (b) any existing Accumulation Shortfall.

  • Controlled insurer means a licensed insurer that is either directly or indirectly

  • Imitation controlled substance means a substance that is

  • Affiliated Fund means with respect to any Investors, each corporation, trust, limited liability company, general or limited partnership or other entity under common control with that Investor (including any such entity with the same general partner or principal investment advisor as that Investor or with a general partner or principal investment advisor that is an Affiliate of the general partner or principal investment advisor of that Investor).