F Reorganization has the meaning set forth in the Recitals.
F Reorganization means a reorganization described by Section 368(a)(1)(F) of the Code. “FCPA” means the Foreign Corrupt Practices Act of 1977, as amended.
F Reorganization means the transaction steps described in the Separation Plan whereby, pursuant to a plan of reorganization within the meaning of Treasury Regulation Section 1.368-2(g), (i) Seller contributes all of the outstanding equity of USCC Services to a newly formed holding company classified as a corporation for U.S. federal income tax purposes that does not hold and has never held more than a de minimis amount of assets and (ii) USCC Services makes an election by properly filing an IRS Form 8832 to change its classification from a corporation to a disregarded entity effective from the day following the contribution (but prior to the transfer of USCC Services to the Company and the Closing Date); which steps (i) and (ii) together are intended to be treated as a reorganization under Section 368(a)(1)(F) of the Code.
Examples of F Reorganization in a sentence
If Buyer does not make the F-Reorganization Election in writing at least ten (10) Business Days prior to the Closing Date, Buyer and Seller shall join in making (or cause to be made), and will take any all actions necessary to effect, a timely election under Section 336(e) of the Code (and any comparable applicable provision of state, local or foreign Law) in respect of Tracer Industries, Inc.
More Definitions of F Reorganization
F Reorganization means a “reorganization” within the meaning of Section 368(a)(1)(F) of the Code;
F Reorganization has the meaning set forth in the preliminary statements to this Agreement.
F Reorganization has the meaning set forth in the recitals of this Agreement.
F Reorganization has the meaning set forth on Exhibit A.
F Reorganization has the meaning specified in Section 6.7(a).
F Reorganization has the meaning specified in Section 8.03(h).
F Reorganization has the meaning specified in Section 9.10(a).