F Reorganization has the meaning set forth in the Recitals.
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.
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.
Examples of F Reorganization in a sentence
Buyer shall have the option, at any time prior to the Satisfaction Date, to notify Seller and Parent whether Buyer would prefer to acquire the equity of USCC Services without undertaking the F Reorganization and without making a Section 338(h)(10) Election with respect to such acquisition (the “Stock Purchase Request”).
More Definitions of F Reorganization
F Reorganization means a “reorganization” within the meaning of Section 368(a)(1)(F) of the Code; Table of Contents
F Reorganization has the meaning set forth in the preliminary statements to 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 means the transaction in which the Party Shareholders and Non-Party Shareholders contributed all of their stock in the Company to the Seller, in exchange for stock in the Seller (issued to the Party Shareholders and Non-Party Shareholders in proportions identical to the manner in which the stock was held by them in the Company), and the election by the Seller to treat the Company as a Qualified Subchapter S Subsidiary for U.S. federal income tax purposes.
F Reorganization means a mere change in identity, form, or place of organization of one corporation, however effected, pursuant to Section 368(a) (1)(F) of the Code.