Examples of Deemed Redemption in a sentence
Accordingly, if the Company elects to redeem less than all of the outstanding Notes as described under Article 16, Holders of the Notes other than Called Notes shall not be entitled to an increased Conversion Rate for conversions of such Notes (on account of the Redemption Notice) during the applicable Redemption Period (except for Deemed Redemption as described in Section 14.01(b)(v)).
The economic exchange is therefore subject to tax under the Deemed Redemption Rule.
Amount due to an entity that was a fellow subsidiary and shareholder of the Company was unsecured, interest-bearing and had fixed repayment terms.
Redemption of Deferred Share Units – Non-U.S. Directors 3.2. The Company shall, on the earlier of the Redemption Date and the Deemed Redemption Date, pay an Eligible Person who is not a U.S. Director and who has Terminated Service cash equal to the Fair Market Value of the Shares on the Redemption Date multiplied by the number of Deferred Share Units to be redeemed on such date, net of any Applicable Withholding Tax.
Ubiquitous services are classified into two categories [56]: local services and remote services.
In cases where the Deemed Redemption Rule does not apply at inception, we believe that certain subsequent transactions should trigger gain recognition.69 For example, as described above, if Parent contributes an appreciated asset to a partnership that owns or acquires Subsidiary stock, the Deemed Redemption Rule should not apply.
The exchange of Subsidiary’s remaining 50 percent interest in Asset A for the other $50 of its stock (assuming no change in values) will be caught by the Deemed Redemption Rule at the time of the liquidating distribution by Partnership.82Consider next the converse of Example 13: Example 14: Parent-Subsidiary Partnership; Parent Stock.
In the case of a Redemption Event, prior to such payment the Corporation shall provide a written notice setting out the Redemption Amount per Class A Series • Preferred Shares, the Deemed Redemption Date, and the name of the chartered bank or trust company at which the Redemption Amount has been or will be deposited (if the Redemption Amount may be deposited).
As discussed more fully below, therefore, we believe that the Deemed Redemption Rule should apply at the time that Subsidiary contributes the appreciated asset and the partnership acquires Parent stock.
In summary, therefore, we believe that the Deemed Redemption Rule should apply if a corporation contributes an appreciated asset to a partnership and the partnership acquires stock in the direct or indirect owner of the corporation.