CTB Election definition

CTB Election means the entity classification election filed by SABMiller to be disregarded as an entity separate from NewCo for U.S. Federal income Tax purposes under Section 7701 of the Code and Treasury Regulation Sections 301.7701-1 through 301.7701-3;

CTB Election has the meaning set forth in the Recitals.

CTB Election shall have the meaning set forth in Section 2.1.2(s) hereof.

Examples of CTB Election in a sentence

• CTB Election Did Not Result in a Transfer of the Funds’ Property That May be Avoided (Counts 19, 20, 21, and 22) Finally, the Defendants argue that the Funds’ fraudulent transfer claims based upon the CTB Election must be dismissed because the Funds do not have a property interest in their tax status that can be subject to an avoidance action under the Bankruptcy Code.

• Specifically, they argue that the CTB Election caused them to incur tax liabilities.253 In their reply briefing, the Defendants argue that the court in Majestic considered and foreclosed this argument, but the Court does not agree.

• Accordingly, more than 60 months will have elapsed before the Court is in a position to contemplate, let alone order, the avoidance the CTB Election.

• Putting aside any other issues that may be implicated by the Defendants’ argument that this Court’s authority to avoid the CTB Election is preempted or otherwise limited by the IRS Treasury Regulations, there does not appear a basis for such an argument in section 301.7701- 3(c)(iv) and therefore, the request to dismiss Counts 19 through 22 on this basis is denied.

• Moreover, the Court can take judicial notice of the Funds’ need to obtain tax compliance and consulting services as a result of the CTB Election and their payment of fees and expenses in connection therewith.

More Definitions of CTB Election

CTB Election is defined in the definition of Holdco REIT Election.

CTB Election means the election under U.S. Treasury Regulations Section 301.7701-3(c) for MidCo to be treated as a corporation for U.S. federal income tax purposes effective on October 29, 2021.

CTB Election has the meaning set forth in section 6.2(j)(i) hereof;

CTB Election has the meaning set forth in Section 6.18(a).

CTB Election shall have the meaning set forth in Section 5.15(a).

CTB Election has the meaning specified in the Recitals hereto.

CTB Election has the meaning set forth on Exhibit A.