F Reorganization definition

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

• DENIED, 386 U.S. 1018 (1967) (a redemption of 48% of a transferor corporation's stock was not a sufficient shift in proprietary interest to disqualify a transaction as a reorganization under section 368(a)(1)(F) ("F Reorganization"), even though only 52% of the transferor's shareholders would hold all the transferee's stock); AETNA CASUALTY AND SURETY CO.

• As noted above, it is our opinion that the Reorganization will qualify as an F Reorganization.

• As noted above, it is our opinion that the Reorganization will qualify as an F Reorganization and that each Fund will be a party to a reorganization.

• For all the foregoing reasons, we believe that the Reorganization will qualify as an F Reorganization.

• Because the Reorganization meets the requirement that an F Reorganization be "a mere change in identity, form, or place of organization of one corporation," the Reorganization also will satisfy the less stringent continuity of business enterprise requirement.

More Definitions of F Reorganization

F Reorganization shall have the meaning set forth in the recitals.

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 specified in Section 6.7(a).

F Reorganization has the meaning specified in Section 9.10(a).

F Reorganization has the meaning specified in Section 8.03(h).