Examples of Corporate Unitholder in a sentence
Unless a valid Tax Election Form is made in accordance with the Tax Act, a Canadian Corporate Unitholder who disposes of Equity Units to SIB LP in consideration for SIB LP Consideration Units pursuant to the Offer will be considered to have disposed of its Equity Units for proceeds of disposition equal to the aggregate of the fair market value, at the time of the disposition, of the SIB LP Consideration Units received.
IPO Co. shall have no obligation to indemnify a Non-Participating Corporate Shareholder or its Related Corporate Unitholder pursuant to this Section 5.a)(3) with respect to the LLC Transfer.
IPO Co. agrees not to dispose of any Corporate Shareholder Interests or any Related Corporate Unitholder (including by dissolution or liquidation of any Related Corporate Unitholder) in a manner, or to take any other action, that causes the LLC Transfer to fail to qualify as a tax-free contribution under Section 351 with respect to any Corporate Shareholder.
Each of the Unit Holders that is not a Related Corporate Unitholder hereby assigns, transfers, conveys and delivers to IPO Co. the Transferred Units, together with all associated rights, privileges, restrictions and obligations in exchange for the Reorganization Shares, with effect as of the Effective Time.
For purposes of this Section 4, the term “Corporate Shareholder” shall exclude any Corporate Shareholder that is listed as an “Investor Parent” in the Operating Agreement if such Corporate Shareholder’s Related Corporate Unitholder only holds Series B Preferred Units.
However, to the extent that any Tax Distributions (as defined in Section 5.1(a) of the Operating Agreement) have not been made by the Operating Company to the applicable Related Corporate Unitholder in order to pay such Taxes or information sufficient to file such Tax Returns has not been distributed to the applicable Related Corporate Unitholder, then IPO Co. shall or shall cause such Tax Returns and Taxes to be filed or paid, as applicable.
In the event that the Operating Company has not issued such New Securities to the Corporate Unitholder within such sixty (60) day period, then the Operating Company shall not thereafter issue such New Securities without again first offering such New Securities to the Rights Holders pursuant to this Section 12.05.